G.R. No. L-30139 - Manila Hotel Co. vs. Court of Industrial Relations

The case consolidates three appeals by certiorari filed on various dates in 1969 involving the Manila Hotel Company (petitioner) and the Pines Hotel Employees Association (CUGCO) as respondent, along with the Court of Industrial Relations.
The disputes arise out of an initial unfair labor practice charge filed by the union against the petitioner, later expanding to include incidents stemming from the abrupt sale of the Pines Hotel and the consequent termination of 86 employees.
The petitions and subsequent proceedings are docketed as L-30139, L-30755, and L-30818 and relate to both the original unfair labor practice dispute and the supplemental issues concerning the payment of retirement gratuity.

In the original unfair labor practice case (L-30755), the respondent union charged the petitioner with unfair practices involving:

Discrimination in the distribution of the 1965 Christmas bonus, where the customary pro rata distribution was altered, resulting in a larger share for Manila Hotel employees compared to those of the Pines Hotel.
Discrimination in the granting of salary adjustments pursuant to the newly enacted Minimum Wage Law (Republic Act 4180), which mandated a two-peso increase in the daily minimum wage.

The industrial court dismissed some counts and found petitioner guilty on two counts, ordering:

A cease-and-desist from committing further unfair labor practices.
The distribution of the Christmas bonus on a pro rata basis.
The implementation of mandated salary adjustments for most employees (except one managerial position) according to the minimum monthly salary of P180.00 until the sale of the Pines Hotel.

On March 28, 1968, the National Development Company sold the Pines Hotel to the Resort Hotels Corporation, leading to an abrupt termination of employment for 86 hotel employees effective the same day.
The sudden termination occurred amidst the pending unfair labor practice case, prompting the union to file an "Urgent Petition with prayer for a temporary restraining order" to stop the dismissal.
The union’s petition was consolidated with the original case, leading to immediate conferences on March 29 and April 2, 1968, where the parties met and negotiated a settlement.

At these conferences, the petitioner explicitly agreed to pay retirement gratuity to all terminated employees:

For the 16 employees with 20 or more years of service: gratuity in accordance with law, computed based on the basic salary on the day of separation.
For the remaining 70 employees (with less than 20 years of service): gratuity at the rate of one month’s salary for every year of service, not exceeding 12 months.

The petitioner’s board of directors convened on April 4 and April 8, 1968, to formalize their commitment by passing resolutions and depositing an initial sum (P100,000.00) with the respondent court.
Subsequent orders by the industrial court (dated December 5, 1968 and February 27, 1969) detailed the specific payment of accrued gratuities, issued further instructions on deductions (including outstanding hotel bills), and provided for individual verification (e.g., by GSIS) before final disbursement.

Challenge of the industrial court’s jurisdiction over the abrupt termination case and subsequent settlement, contending that no employer-employee relationship existed at the time of filing.
Argument that the union’s counsel lacked standing to file an unfair labor practice charge directly with the court.
Claim that the union’s demand had been settled, waived, or was otherwise extinguished under the terms of the settlement agreement.

The petitioner’s own acquiescence to the settlement by agreeing to the payment of gratuities.
The subsequent confirmation of jurisdiction by the industrial court and the practical resolution of the parties’ dispute.

Whether the petitioner’s altered method of distributing the 1965 Christmas bonus, which deviated from the previously established pro rata system, amounted to discrimination.
Whether the differential treatment in granting salary adjustments, particularly in light of the Minimum Wage Law (RA 4180), constituted an unfair labor practice.

Whether the abrupt termination of employment upon the sale of the Pines Hotel without advanced notice violated the employees’ rights under the existing collective bargaining agreements.
Whether the union was entitled to seek a temporary restraining order to prevent immediate dismissal despite the pending unfair labor practice case.

Whether the industrial court had proper jurisdiction to address both the unfair labor practice charges and the supplemental issues arising from the sale and termination.
Whether the petitioner’s objections regarding jurisdiction and the procedural manner in which the union’s urgent petition was filed were valid.

Whether payment of the retirement gratuity should be executed directly by the court (and not through the customary Government Service Insurance System) despite potential outstanding deductions such as hotel bills.
Whether the petitioner’s alleged challenges on the propriety and jurisdiction of the payment orders should affect the resolution of pending claims.