Facts:

The case involves Campos Rueda Corporation as the petitioner and Hon. Jose S. Bautista, Hon. Baltazar M. Villanueva, Hon. Arsenio I. Martinez, Hon. Amando C. Bugayong as associate judges of the Court of Industrial Relations, and Manuel Muyot as the respondent. The events leading to the case began when Manuel Muyot was employed by Campos Rueda Corporation at its gasoline station located at 1012 Azcarraga St. (now Recto Avenue), Manila. He worked there from May 21, 1949, to May 31, 1953, earning a monthly salary of P200.00 until May 31, 1953, after which his salary increased to P230.00 from June 1 to December 31, 1953. On November 26, 1958, Muyot filed a complaint against the petitioner with the Court of Industrial Relations (Case No. 1140-V), seeking compensation for alleged unpaid overtime, Sunday, and holiday services rendered during his employment.

In response, Campos Rueda Corporation filed a motion to dismiss the complaint on December 8, 1958, arguing that the claims w...

Facts:

Employment Details:

• Respondent Manuel Muyot was employed by petitioner Campos Rueda Corporation at its gasoline station on Azcarraga Street (now Recto Avenue), Manila.
• His employment period was from May 21, 1949, to December 31, 1953, with a monthly salary of P200.00 from May 21, 1949, to May 31, 1953, and P230.00 from June 1 to December 31, 1953.

Filing of Complaint:

• On November 26, 1958, Muyot filed a complaint (Case No. 1140-V) with the Court of Industrial Relations (CIR) to recover compensation for alleged overtime, Sunday, and holiday services rendered during his employment.

Motion to Dismiss:

• On December 8, 1958, petitioner filed a motion to dismiss the complaint on the following grounds:
  • The claims were barred by the statute of limitations.
  • The claims were barred by prior decisions in related cases (Case No. C-4364, Civil Case No. 30138, and Civil Case No. 36060).

Opposition to Motion to Dismiss:

• Muyot opposed the motion, arguing that the prior decisions were rendered by courts without jurisdiction and thus did not constitute res judicata. He also claimed that the statute of limitations was interrupted when he filed cases with the Department of Labor on October 27, 1955, and with the Court of First Instance on July 7, 1956.

Supplementary Motion to Dismiss:

• On March 17, 1959, petitioner filed a supplementary motion to dismiss, arguing that the CIR lacked jurisdiction because Muyot’s employment had ended on December 31, 1953, and he was not seeking reinstatement.

CIR Rulings:

• On August 3, 1959, the CIR, through Judge Arsenio I. Martinez, denied the motion to dismiss and required petitioner to answer the complaint.
• On August 15, 1959, the CIR en banc denied petitioner’s motion for reconsideration.

Subpoena Duces Tecum:

• During the trial, Muyot requested a subpoena duces tecum for the daily time records of employees at the Super Service Station for 1952-1953.
• Petitioner moved to quash the subpoena, arguing it was overly broad, irrelevant, and that Muyot had not advanced the cost of producing the records.
• On June 24, 1960, the CIR denied the motion to quash, and on July 11, 1960, the CIR en banc denied petitioner’s motion for reconsideration.

Petition for Certiorari and Prohibition:

• Petitioner filed the present action to annul the CIR’s orders of August 3 and 15, 1959, and June 24 and July 11, 1960.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction of the CIR:

   • The CIR’s jurisdiction is limited to cases involving labor disputes, including claims arising from an existing or sought-to-be-reestablished employer-employee relationship.
   • Once the employment relationship is terminated and no reinstatement is sought, claims for unpaid wages or overtime become mere money claims, which fall under the jurisdiction of regular courts.

2. Amendment of Complaint:

   • Jurisdiction is determined by the allegations in the original complaint. An amendment cannot confer jurisdiction if the original complaint did not allege facts sufficient to establish jurisdiction.

3. Res Judicata and Statute of Limitations:

   • The Court deemed it unnecessary to rule on these issues, as the lack of jurisdiction over the subject matter was dispositive of the case.

4. Subpoena Duces Tecum:

   • The Court did not address the validity of the subpoena, as the case was resolved on jurisdictional grounds.

Conclusion:

The Supreme Court annulled the CIR’s orders and ruled that the CIR lacked jurisdiction over Muyot’s claims. The case was dismissed, and costs were awarded against Muyot.