G.R. No. 48524 - Manila Hotel Employees Association vs. Manila Hotel Co.

The case involves the Manila Hotel Employees Association as petitioner and the Manila Hotel Company together with the Court of Industrial Relations as respondents.
The dispute arose from labor controversies in the Manila Hotel, a subsidiary of the government-controlled Manila Railroad Company.
The petitioner, a duly authorized labor organization under Commonwealth Act No. 213, initially sought the adoption of minimum compensation rates and a system of automatic salary increases for hotel employees.

Prior to 1940, the association filed a petition requesting wage adjustments and service-based salary increases for employees and laborers of the hotel.
On September 9, 1940, a letter from the Secretary to the President advised Mr. Francisco David, president of the association, that further wage increases were not advisable because of severe business losses (estimated at not less than P100,000) and unsettled world conditions.
The management of the hotel subsequently took actions that the association objected to, leading to further unrest.

The petitioner alleged that Francisco Solivar was dismissed on August 2, 1940, without just cause to curb union activities.
In a bid to curb union influence, the management reportedly transferred Francisco David from the Manila Hotel to the Mayon Hotel, Legaspi, Albay, without a commensurate salary increase.
The petitioner claimed that on November 4, 1940, during the planning of a manifestation to present grievances, the management used special policemen to drive away on-duty employees to give the false impression of a strike.
The management further prevented employees from re-entering the hotel premises by barring those residing in the dormitory building, and later informed them that they were no longer eligible for readmission.

The association requested a conference and subsequently sent a petition for intervention to the Office of the President and the general manager of the Manila Railroad Company, urging the reinstatement of the dismissed employees and an investigation into their case.
An answer was filed by the Manila Hotel Company denying the allegations, asserting that:

The petition failed to state a sufficient cause of action.
As a subsidiary of a government-owned enterprise, its employees were effectively government employees.
The employees had effectively abandoned their posts on November 4, 1940, thus forfeiting their status.

Following partial amicable settlement, the dispute was narrowed to the remaining seven employees, including the cases of Francisco David and Francisco Solivar, with issues remaining on back wages and the justification of their dismissed status.
Administrative correspondence from Secretary Vargas and Assistant Secretary Benitez later reinforced the management’s position regarding the dismissal and transfer of the employees.
A motion to dismiss the petition was filed by the respondent’s attorney, claiming that matters concerning Francisco David and Francisco Solivar had already been resolved by the Office of the President, and that the Court of Industrial Relations lacked jurisdiction on those grounds.
The Court of Industrial Relations, through Judge Generoso, dismissed the case on the reasoning that the dispute did not constitute a controversy warranting its intervention, instead deeming it an internal managerial matter.
A motion for reconsideration filed by the petitioner was subsequently denied, leading to a petition for mandamus to compel the Court of Industrial Relations to decide on the merits of the case.

Whether the Court of Industrial Relations (CIR) has jurisdiction over disputes involving employees and laborers of a government-controlled corporation, particularly when the enterprise is partly or largely owned by the government.
The implication of the President’s letters, which were directed at the Manila Railroad Company, on the jurisdiction over a subsidiary such as the Manila Hotel Company.

Whether the dispute, arising from wage differences, suspension, and dismissal of employees, falls within the ambit of Commonwealth Act No. 103 (as amended), which confers powers to the CIR.
The issue of whether the actions undertaken by the hotel's management, including dismissals and transfers, constitute violations of statutory provisions protecting labor rights.

How the double role of the management (as both employer and de facto adjudicator of disputes) impacts the proper resolution of the labor controversy.
Whether the existence of an amicable settlement (which readmitted the majority of employees) affects the CIR’s continued jurisdiction over the remaining claims.