Title
Bay View Hotel, Inc. vs. Manila Hotel Workers' Union-PTGWO
Case
G.R. No. L-21803
Decision Date
Dec 17, 1966
Bay View Hotel faced union grievances over unpaid overtime, illegal deductions, service charge refunds, denied vacation leave, and unfair labor practices, including dismissals and lockouts. The CIR asserted jurisdiction, upheld by the Supreme Court, to resolve all claims under labor laws, avoiding split jurisdiction and ensuring efficient dispute resolution.

Case Digest (G.R. No. L-21803)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
    • Petitioner: Bay View Hotel, Inc., operator of the Manila Hotel.
    • Respondent: Manila Hotel Workers' Union-PTGWO.
    • Respondents in the lower court: Judges of the Court of Industrial Relations (CIR).
  • Union's Grievances Filed on September 27, 1962
    • Violation of Commonwealth Act No. 444 (Eight-Hour Labor Law) due to non-payment of full overtime compensation for employees working beyond eight hours daily, including Sundays and legal holidays.
    • Violation of Sec. 10, letters (f) and (g), of Republic Act No. 602 (Minimum Wage Law) by unlawfully deducting P2.00 monthly from each employee for medical fees without their consent.
    • Failure to pay or fully refund employees the extra "service charge" collected from customers, which replaces tips for waiters and roomboys.
    • Non-compliance with granting three days of vacation leave per year under the Collective Bargaining Contract with a different union recognized as the collective bargaining agency.
    • Alleged illegal dismissal of 65 union members, including key officers, without just cause or due to union activities, among whom 41 were locked out illegally (in Laundry Department and Bamboo Room) in August and September 1962.
  • Procedural History
    • January 16, 1963: Petitioner moved to dismiss the case on grounds:
      • CIR lacked jurisdiction.
      • The dismissal and lock-out claims were already the subject of another ULP case (No. 3387-ULP) in another CIR branch.
    • March 11, 1963: CIR Judge Emiliano C. Tabigne sustained the motion, dismissing the petition for lack of jurisdiction.
    • August 15, 1963: CIR en banc reversed the dismissal, declaring jurisdiction under Commonwealth Act No. 103 and citing the Prisco case, emphasizing:
      • Number of complainants exceed 30.
      • Employees still employed or seeking reinstatement.
      • Claims arise from employment relationship and may cause strike or lock-out.
    • Dissent: Judge Tabigne dissented from the en banc decision.
    • Petitioner elevated the case to the Supreme Court via certiorari.
  • Jurisprudential Context Cited
    • PAFLU vs. Tan (1956): CIR jurisdiction limited to:
      • Labor disputes in industries indispensable to national interest certified by the President.
      • Minimum wage controversies (RA 602).
      • Hours of employment disputes (CA 444).
      • Unfair labor practice (ULP) charges (RA 875).
    • Prisco vs. CIR (1960):
      • CIR jurisdiction extends to all claims connected to employment if employer-employee relationship exists or reinstatement is sought.
      • After termination without reinstatement, claims become money claims for regular courts.
    • Sy Huan vs. Bautista (1961) and Campos vs. Manila Railroad Co. (1962): Reinforced and clarified the scope of CIR jurisdiction requiring:
      • Existing employer-employee relationship or reinstatement sought.
      • Disputes either certified as national interest, ULP-related, or arising under Minimum Wage Law or Eight-Hour Labor Law.
  • Specific Analysis of Union Claims by the Supreme Court
    • Employer-employee relationship exists, and dismissed employees seek reinstatement.
    • Claims of violation of Eight-Hour Law and Minimum Wage Law fall squarely within CIR jurisdiction (per Campos).
    • Alleged dismissals and lockouts constitute unfair labor practice charges, within CIR jurisdiction.
    • Admission by union that ULP investigations already pending in another CIR branch does not remove existing jurisdiction over related claims filed earlier.
    • Additional claims (non-refund of service charge and vacation leave violations) may be outside CIR’s jurisdiction standing alone but are considered part of the same employment dispute and thus within its jurisdiction as a whole.
  • Petitioner's Argument and Court's Responding Doctrine
    • Petitioner's claim that CIR jurisdiction over one claim does not extend to all claims raised in the complaint.
    • Supreme Court rejects "piecemeal" jurisdiction approach, emphasizing efficiency, avoidance of multiplicity of suits, and protection of employee rights by allowing CIR to hear all claims arising from the same employment relationship.

Issues:

  • Whether the Court of Industrial Relations has jurisdiction over the grievances filed by the Manila Hotel Workers' Union against Bay View Hotel, Inc., which include overtime compensation, unlawful wage deductions, non-refund of service charges, failure to grant vacation leave, and unfair labor practices involving union member dismissals and lockouts.
  • Whether the pendency of another unfair labor practice case before a different branch of the CIR affects the jurisdiction of the CIR over the present complaint.
  • Whether the CIR's jurisdiction over certain claims arising under labor laws extends to all claims arising out of the same employment relationship, or if jurisdiction should be split between the CIR and regular courts.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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