Title
Goseco vs. Court of Industrial Relations
Case
G.R. No. 46673
Decision Date
Sep 13, 1939
Dispute over tenant shares in sugar-cane crops; CIR amended decision for fairness, upheld by Supreme Court under equity principles.
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Case Digest (G.R. No. 46673)

Facts:

  1. Parties Involved:

    • Petitioner: Andres P. Goseco (lessee of the hacienda "El Prado").
    • Respondents: Court of Industrial Relations (CIR), Roman Belleza, and 72 other tenants.
    • Other Party: Martin Gonzales (owner of the hacienda "El Prado").
  2. Dispute:

    • The dispute arose over the tenants' share in the sugar-cane crops from the hacienda "El Prado."
    • The Secretary of Labor certified the dispute to the CIR on August 27, 1937.
  3. CIR Decision (December 28, 1937):

    • The CIR ordered Andres Goseco to pay tenants a minimum of P1.70 per ton for new plant cane and P1 per ton for ratoon cane (if cultivated by the tenant), without charging for fertilizer costs.
  4. Motion for Reconsideration:

    • On February 11, 1938, the tenants filed a motion for reconsideration.
    • The hearing was postponed to March 3, 1938, at the request of Goseco's counsel.
    • On March 10, 1938, Goseco's counsel filed an opposition to the motion.
  5. Amended Decision (February 28, 1939):

    • The CIR amended its decision, setting the rate for ratoon cane at P1.50 per ton, citing fairness and equity.
  6. Jurisdictional Challenge:

    • Goseco challenged the CIR's jurisdiction, arguing that the December 28, 1937, decision had become final after 10 days and could not be reconsidered.
    • The CIR denied the motion, stating that it acted in the interest of justice and equity.
  7. Petition for Certiorari:

    • Goseco filed a petition for certiorari to annul the CIR's amended order, claiming it was issued without jurisdiction.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of the CIR:

    • Section 17 of Commonwealth Act No. 103 explicitly allows the CIR to alter, modify, or set aside its awards, orders, or decisions at any time during their effectiveness, upon application and after a hearing.
    • The CIR's power to extend prescribed time and disregard technicalities is consistent with its role as a court of equity and justice.
  2. Purpose of Commonwealth Act No. 103:

    • The law aims to settle disputes between employers and employees, landlords and tenants, with a focus on justice, equity, and the substantial merits of the case.
    • The CIR is not bound by rigid procedural rules and may act in a manner it deems just and equitable.
  3. Finality of Decisions:

    • The CIR's decisions are not immune from revision or amendment, especially when such amendments are necessary to achieve fairness and equity.
    • The Court emphasized that the CIR's actions were in line with the spirit of the law, which prioritizes the welfare of laborers and tenants.
  4. Self-Imposed Limitation of the Supreme Court:

    • The Supreme Court declined to override the CIR's judgment, recognizing the latter's expertise and discretion in resolving industrial and agricultural disputes.


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