Case Digest (G.R. No. L-22791)
Facts:
The case involves petitioners Cirilo Barnachea, Paulino Gonzales, Bernardo Gonzales, and Ricardo Gorospe against respondents Hon. Emiliano C. Tabigne and Sin Hap Lee & Co. The events leading to this case began with two complaints filed in the Court of Industrial Relations. The first complaint, Case 1259-V, was initiated by the National Federation of Labor Unions and/or Benita Bulaon against Sin Hap Hua & Co., while the second complaint, Case 1260-V, was filed by the National Labor Union and/or Cirilo Barnachea against Sin Hap Lee & Co. Both companies are sister companies. With the consent of the parties and the approval of the court, these cases were jointly tried before a commissioner appointed by the court. On October 19, 1963, Judge Jose S. Bautista rendered a judgment dismissing Case 1259-V and granting the petition for overtime pay in Case 1260-V, directing the chief of the examining division to compute the necessary amounts and submit a report. The decision ...
Case Digest (G.R. No. L-22791)
Facts:
Parties Involved:
- Petitioners: Cirilo Barnachea, Paulino Gonzales, Bernardo Gonzales, and Ricardo Gorospe.
- Respondents: Hon. Emiliano C. Tabigne (Judge of the Court of Industrial Relations) and Sin Hap Lee & Co.
Nature of the Case:
- The case involves a claim for wage differentials and overtime compensation filed by the petitioners against Sin Hap Lee & Co.
Procedural Background:
- Two complaints were filed in the Court of Industrial Relations (CIR):
- Case 1259-V: National Federation of Labor Unions and/or Benita Bulaon, et al. vs. Sin Hap Hua & Co.
- Case 1260-V: National Labor Union and/or Cirilo Barnachea, et al. vs. Sin Hap Lee & Co.
- The cases were jointly tried before a court-appointed commissioner.
- On October 19, 1963, Judge Jose S. Bautista rendered a decision:
- Dismissed Case 1259-V.
- Granted the petition for overtime pay in Case 1260-V and directed the computation of overtime pay.
- The decision in Case 1259-V became final.
- Sin Hap Lee & Co. moved for reconsideration in Case 1260-V.
- On January 23, 1964, the CIR en banc, through Judge Emiliano C. Tabigne, reversed Judge Bautista's decision and dismissed Case 1260-V for "lack of substantial evidence."
- Two complaints were filed in the Court of Industrial Relations (CIR):
Evidence Presented:
- Time records and payrolls showed that overtime work was recorded and paid.
- Petitioners admitted signing the time records and payrolls without compulsion or intimidation.
- Petitioners claimed they did not notice the entries in the payrolls or that the entries were incorrect.
- The CIR en banc found the documentary evidence (time records and payrolls) more credible than the conflicting oral testimonies of the petitioners.
Period Covered:
- The claim for overtime pay covered the period from 1956 to 1959.
Issue:
- Whether the Court of Industrial Relations en banc erred in dismissing the petitioners' claim for overtime pay based on the finding that the claim lacked substantial evidence.
- Whether the documentary evidence (time records and payrolls) outweighed the oral testimonies of the petitioners.
Ruling:
The Supreme Court affirmed the resolution of the Court of Industrial Relations en banc, dismissing the petitioners' claim for overtime pay. The Court held that the findings of fact by the CIR, supported by substantial evidence (time records and payrolls), should not be disturbed.
Ratio:
Substantial Evidence Rule:
- On appeal from a decision of the Court of Industrial Relations, the Supreme Court's function is limited to determining whether the findings of fact are supported by substantial evidence. If they are, the judgment must be affirmed.
- In this case, the time records and payrolls constituted substantial evidence supporting the CIR's decision.
Credibility of Evidence:
- In the presence of conflicting evidence (oral testimonies vs. documentary evidence), the CIR gave more weight to the written documents (time records and payrolls).
- The petitioners' testimonies were found to be conflicting and unreliable, while the documentary evidence was consistent and credible.
Finality of Findings of Fact:
- The Supreme Court reiterated that it will not disturb the findings of fact of the CIR when such findings are supported by substantial evidence, as in this case.