Case Digest (G.R. No. L-16025)
Facts:
The case involves Fookien Times Company, Inc. and Go Puan Seng as petitioners against the Court of Industrial Relations and Flora Cruz Gallero as respondents. The events leading to this case began when Flora Cruz Gallero, who was employed by Fookien Times Company, Inc. from July 9, 1952, until her dismissal on September 5, 1958, filed a complaint on November 13, 1958. In her complaint, she sought claims for overtime pay for the period from 1952 to 1957, maternity pay for three specific occasions (July 16, 1954, October 8, 1955, and June 4, 1958), separation pay, and sick and vacation leave pay. Upon receiving the complaint, the respondents filed a motion to dismiss, arguing that the Court of Industrial Relations lacked jurisdiction over the claims for separation pay, sick and vacation leave pay, overtime wages, and maternity leave pay. On August 4, 1959, the court dismissed the claims for sick and vacation leave pay and maternity leave pay but required the respondents to answ...
Case Digest (G.R. No. L-16025)
Facts:
- Employment Details: Flora Cruz Gallero was employed by Fookien Times Company, Inc. starting July 9, 1952, and was dismissed on September 5, 1958.
- Claims Filed: Gallero filed a complaint in the Court of Industrial Relations (CIR) on November 13, 1958, seeking:
- Overtime pay for the period 1952 to 1957.
- Maternity pay for three occasions: July 16, 1954, October 8, 1955, and June 4, 1958.
- Separation pay.
- Sick and vacation leave pay.
- Motion to Dismiss: The respondents (Fookien Times Company, Inc. and Go Puan Seng) filed a motion to dismiss, arguing that the CIR lacked jurisdiction over the claims.
- CIR Ruling: On August 4, 1959, the CIR dismissed the claims for sick and vacation leave pay and maternity leave pay but required the respondents to answer the claims for separation pay and overtime compensation.
- Jurisdictional Challenge: The petitioners contested the CIR's jurisdiction over the claims for separation pay and overtime compensation, arguing that these were ordinary money claims falling under the jurisdiction of regular courts.
Issue:
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Ruling:
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Ratio:
- Jurisdiction of the CIR: The Court reiterated that the CIR's jurisdiction is limited to cases involving unfair labor practices, labor disputes, and matters arising from employer-employee relationships that affect national interest. Ordinary money claims, such as those for separation pay and overtime compensation, do not fall within the CIR's jurisdiction.
- Precedents: The Court cited several precedents, including Mindanao Bus Employees Labor Union vs. Mindanao Bus Co., Aguilar vs. Salumbides, and Roman Catholic Archbishop of Manila vs. Yanson, which established that claims for overtime wages, wage differentials, and separation pay are ordinary money claims cognizable by regular courts.
- Nature of Claims: Since Gallero's claims did not involve unfair labor practices or reinstatement, and there was no indication of her membership in a labor organization with contractual rights, the claims were deemed ordinary and outside the CIR's jurisdiction.