Case Digest (G.R. No. L-17185)
Facts:
Government Service Insurance System v. GSIS Employees' Association and Court of Industrial Relations, G.R. No. L-17185. February 28, 1964, the Supreme Court En Banc, Padilla, J., writing for the Court.The dispute arose from a judgment of the Court of Industrial Relations (CIR) rendered 29 June 1959 in Case No. 896‑V in favor of the GSIS Employees' Association (GSISEA) on 21 demands that had prompted a strike on 17 June 1953. The CIR awarded, among other things, specific monthly salary increases and family allowances; the judgment was certified to the CIR by the Acting Secretary of Labor. On 6 July 1959 the Government Service Insurance System (GSIS), then the respondent below, filed a motion for clarification and reconsideration contesting (1) whether the recognition of collective bargaining required GSIS management to bargain on matters governed by law, (2) the scope and retroactivity of the salary increases ordered, and (3) the grant of family allowances to certain employees and an adverse observation regarding GSIS' finances.
On 13 August 1959 the CIR issued an order clarifying that recognition of collective bargaining did not oblige acceptance of terms that could not lawfully be bargained; that salary increases granted during the pendency of the case were independent of the judgment's increases; and it denied the motion to delete the financial observation, directing the parties to indicate whether they would withdraw or submit their motions to the CIR en banc. GSIS moved on 16 October 1959 to set its motion for clarification and reconsideration for hearing before the CIR en banc; GSISEA filed a motion for reconsideration as well. The CIR en banc, by resolution promulgated 14 March 1960, denied GSIS' motion for clarification and reconsideration, held that only the family‑allowance point was submitted en banc, and ruled that a motion for clarification did not suspend the period to file a motion for reconsideration or to appeal.
GSIS filed notice of appeal on 22 July 1960 and a petition for review (appeal by certiorari under Rule 44) on 26 July 1960, asserting lack of CIR jurisdiction, that the motion for clarification tolled the period to move for reconsideration or appeal, and that the CIR erred in awarding salary increases. GSISEA moved to dismiss on grounds the CIR's rulings were final and that the jurisdictional issue had been settled by this Court in GSIS v. Hon. Modesto Castillo et al., 98 Phil. 876 (27 Apr. 1956). This Court gave due cours...(Subscriber-Only)
Issues:
- Did the Court of Industrial Relations have jurisdiction over the dispute between GSIS and GSISEA?
- Does the filing of a motion for clarification of the CIR's judgment suspend the period for filing a motion for reconsideration or appeal?
- Were the CIR's awards of salary increases reviewable on the merits in this petition gi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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