Title
Barnachea vs. Tabigne
Case
G.R. No. L-22791
Decision Date
May 16, 1967
Workers claimed unpaid overtime from 1956-1959; CIR dismissed due to credible payroll records outweighing conflicting testimonies, upheld by SC.
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Case Digest (G.R. No. L-22791)

Facts:

The case involves petitioners who claimed wage differentials and overtime compensation for work rendered between 1956 and 1959. Originally, two complaints were consolidated in the Court of Industrial Relations with the participation of sister companies as respondents. One case (1259‑V) was dismissed, while in the other (1260‑V) the presiding judge initially granted overtime pay. However, upon a motion for reconsideration by the respondent in Case 1260‑V, the Court of Industrial Relations en banc reversed the initial favorable ruling, dismissing the claim for overtime pay “for lack of substantial evidence.” The en banc decision relied heavily on documentary evidence—time records and payrolls—that showed overtime work duly recorded and compensated, and which petitioners themselves had signed without contesting any inaccuracies at the time. In contrast, the petitioners’ oral testimonies were conflicting regarding the entries in the payrolls, with some witnesses asserting that the documents had no entries at the moment of their signing, while others admitted ignorance of the entries but nevertheless affixed their signatures.

Issue:

The primary issue was whether the documented time records and payrolls, which indicated that overtime work was rendered and duly compensated, constituted substantial evidence to support the court’s findings in the face of conflicting oral testimonies. Additionally, the case raised the question of whether a trial court's finding, when supported by a preponderance of substantial documentary evidence, should be disturbed despite contradictory witness accounts.

Ruling:

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Ratio:

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Doctrine:

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