Facts:

The case in question is a petition for certiorari filed by the Betting Ushers Union (PLUM) against the Jai Alai Corporation of the Philippines and the Court of Industrial Relations, under G.R. No. L-9330, decided on June 29, 1957. The central issue arose from a resolution of the Court of Industrial Relations which dismissed PLUM’s petition for the Jai Alai Corporation to pay minimum wages to its betting ushers as mandated by Republic Act No. 602. Prior to this petition, an investigation had been initiated by the Wage Administration Service (WAS) regarding the corporation’s obligation to pay minimum wages. However, the corporation sought an injunction against the investigation through the Court of First Instance of Manila, which ruled that the betting ushers, working under a concession, were not actual employees of the corporation and thus not entitled to minimum wage protections. This injunction simultaneously denied a counterclaim by the betting ushers' association seeking

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Facts:

Background of the Case

• The Betting Ushers Union (PLUM) filed a petition against the Jai Alai Corporation of the Philippines in the Court of Industrial Relations.
• The petition sought to have the corporation pay its betting ushers the minimum wage as fixed in Republic Act No. 602.
• Prior to the petition, the acting chief of the Wage Administration Service (WAS) was investigating the corporation for its compliance with minimum wage laws.

Controversy over Employment Status and Minimum Wage

• A complaint by the corporation led the Court of First Instance in Manila, in Civil Case No. 24155, to join the WAS investigation.
• The court ruled that the betting ushers, operating under a concession, were not employees of the corporation and therefore not entitled to the legal minimum wage.
• The judgment in the civil case affected the proceedings by denying the betting ushers their claim for minimum wages.

Filing of the Petition and Subsequent Pleadings

• Despite the civil case ruling, the Betting Ushers’ Association (apparently identical with the union) filed a petition in the Industrial Court seeking payment of the previously denied minimum wages.
• The corporation raised multiple defenses:
• Lack of jurisdiction.
• Lack of cause of action.
• Pendency of another suit in the Court of First Instance.
• After the period for appeal in the civil case had expired, the corporation amended its defense by asserting res judicata, arguing that the judgment from the Court of First Instance was already final regarding the minimum wage claim.
• The corporation also filed a supplemental motion to dismiss based on a letter allegedly signed by 64 out of 65 union members, authorizing dismissal of the case.

Conflict Within the Union and the Role of Counsel

• The union’s board of directors, acting on a resolution of its members, filed a motion for dismissal “with prejudice and without pronouncement as to costs.”
• Attorneys Rafael and Ilustre, previously handling the case for the union, opposed the dismissal motion.
• They claimed to be unaware of the authenticity or the origin of the letter from the 64 members.
• They argued that proper authorization or notice should have been given if the union intended to withdraw or dismiss the case.
• A hearing on the motion was held; however, the attorneys did not appear, resulting in the lower court ordering dismissal on March 30, 1955.

Subsequent Developments and Evidence on Union’s Consent

• On April 5, 1955, the attorneys filed a motion for reconsideration of the dismissal.
• In their written argument, the attorneys alleged that:
• Only 40 members had signed a resolution that seemingly opposed the dismissal.
• The signatures on the resolution opposing dismissal were “imposed” and signed under a misunderstanding regarding the purpose of the resolution (believing it was related to uniform cost reimbursement).
• The corporation countered these allegations by presenting supporting affidavits:
• Sworn statements from more than three-fourths of the 40 signers indicated that the purpose was indeed to secure dismissal.
• Additional sworn statements from 28 members reiterated their desire for dismissal with prejudice, in accordance with the final judgment in the Court of First Instance.
• In total, 56 out of the 65 members (more than four-fifths) were found to have indeed desired the dismissal of the case.

Court’s Consideration of the Case and the Appeal

• The Industrial Court, sitting en banc, handed down its resolution on June 18, 1955, denying the attorneys’ motion for reconsideration.
• The attorneys subsequently appealed to the Supreme Court by certiorari.
• Their contention on appeal included three key issues:
• That the dismissal effectively amounted to a waiver of the betting ushers’ legal right to a minimum wage.
• That due process was denied because the case was dismissed without a trial on the merits.
• That the dismissal improperly foreclosed the question of jurisdiction.

Issue:

Proper Authority and Consent for Dismissal

• Whether the dismissal of the case was valid when it was filed on a motion by the union (through its board of directors) that reflected the wishes of an overwhelming majority of its members.
• Whether the dissenting views of a minority of the members, as represented by the attorneys, were sufficient to challenge the union’s collective decision.

Due Process and Trial on the Merits

• Whether the dismissal of the case without a trial on the merits resulted in a denial of due process to the petitioning union.
• Whether the attorneys’ non-appearance at the hearing for the motion to dismiss deprived the union of a fair opportunity to argue or reconsider their decision.

Jurisdictional and Res Judicata Concerns

• Whether the dismissal of the case by the Industrial Court improperly precluded the proper joinder or the exercise of jurisdiction over the dispute regarding the minimum wage claim.
• Whether the existence of a pending case in the Court of First Instance or the finality of its judgment (res judicata) should have determined the merits ahead of the union’s resolution.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)