Facts:

In the case of Bank of America (Manila Branch) vs. The Hon. Court of Industrial Relations and Philippine Federation of Labor (G.R. No. L-16904), the Philippine Federation of Labor, hereafter referred to as the "Federation," filed a petition on May 30, 1959, with the Court of Industrial Relations. The petition sought payment for unpaid wages for overtime work performed by five of its members, who were security guards employed by the petitioner bank, during Sundays and legal holidays from 1947 up until the date of the petition. The Federation pointed out that they had previously requested a conference with the bank's management to discuss various grievances, including the unpaid wages for overtime work and issues related to unfair labor practices associated with salary and wage increases. However, the management of the Bank of America refused to engage in this conference.

On June 9, 1959, the Bank of America filed a motion to dismiss the Federation's petition, cl

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Facts:

Background of the Case

• The Philippine Federation of Labor ("Federation"), a registered labor union, filed a petition on 30 May 1959 before the Court of Industrial Relations.
• The petition sought payment of unpaid overtime wages for work done on Sundays and legal holidays by five security guards employed by the petitioner, Bank of America (Manila Branch), spanning from 1947 until the filing date.
• The petition also alleged that the bank management refused to hold a grievance conference to address issues such as unpaid overtime wages and alleged unfair labor practices in the matter of salary and wage increases, thereby compounding their claims.

Procedural History

• On 9 June 1959, the bank moved for the dismissal of the petition on the grounds of lack of jurisdiction, citing the rule from Chua Workers' Union (NLU) vs. City Automotive Company and a precedent case (G.R. No. L-11655, dated 29 April 1959).
• The bank further argued that, among more than 180 employees, only five were represented by the Federation, questioning the representative nature of the complaint.
• On 20 June 1959, the Federation objected to the dismissal, invoking precedents such as NASSCO vs. Almin (G.R. No. L-9055, dated 28 November 1958) and Gomez vs. North Camarines Lumber Co., Inc. (104 Phil., 294), emphasizing that disputes involving unpaid wages for overtime work fall within the jurisdiction of the Court of Industrial Relations.

Decision of the Lower Court

• On 10 September 1959, the trial court dismissed the petition.
• The dismissal was based on the reasoning that the trial court had lost jurisdiction over claims for unpaid overtime or wage differentials after the effectivity of Rip. Act No. 875 on 17 June 1953.
• The dismissal order clarified that although the court retained exclusive jurisdiction over cases involving unfair labor practices and certain grievance-related matters under specific sections of R.A. No. 875, the petition did not meet the formal requisites required under the law.
• The order noted that the dismissal did not preclude the filing of charges for unfair labor acts against the bank.

Subsequent Developments

• On 15 September 1959, the Federation sought reconsideration of the dismissal, arguing that the order was contrary to law and requesting additional time to submit a memorandum.
• The Federation’s memorandum, submitted on 22 September 1959, included reliance on the ruling in Monares vs. CNS Enterprises (G.R. No. L-117491, dated 29 May 1958).
• Ultimately, on 12 March 1960, the Court of Industrial Relations, sitting en banc, rendered an order affirming its jurisdiction to hear the case involving unpaid overtime work claims.

Issue:

Jurisdictional Inquiry

• Whether the Court of Industrial Relations has jurisdiction to adjudicate claims for unpaid overtime wages rendered on Sundays and legal holidays by employees who have been continuously employed by the petitioner bank from 1947 to the present.
• Whether the claim for unpaid wages, especially for those services performed on special days (holidays and Sundays), constitutes a grievance with the potential to lead to a strike, thereby falling within the jurisdiction of the industrial court.

Validity of the Petition

• Whether the petition, as filed by the Federation, meets the requisite legal formalities and standards mandated under the applicable labor laws and relevant provisions of R.A. No. 875 and other labor statutes.
• The issue also touches upon the implications of representativeness, given that only five out of more than 180 employees were involved.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)