G.R. No. 199972 - De Lima vs. Court of Appeals

Tomas Gutierrez, a former employee of the Manila Railroad Company, died in April 1945.
His heirs filed a claim before the Court of Industrial Relations (CIR) for the money equivalent of his unused vacation and sick leave.
The claim was initially denied by the company, but upon the claimants’ appeal—transforming the issue into a labor dispute—the CIR ruled in their favor.
The CIR based its decision on longstanding company practice and a circular issued by the Manager of the Railroad Company, which provided for the payment of such benefits.
The ruling was further supported by the amendment of Sec. 286 of the Revised Administrative Code (through Republic Act No. 611), which eliminated the forfeiture of accrued vacation and sick leave upon separation from service.

Pedro de la Cruz, then incoming freight clerk at the company’s Naga office, faced an incident on April 11, 1947, involving the processing of waybills for flour shipments.
Of the 400 sacks of flour involved, 200 sacks bypassed his office—being delivered directly to the consignee—resulting in his suspension from August 28, 1947, until December 5, 1947.
Despite the irregularity, payment for the freight was remitted by the consignee, leaving the company without a financial loss.
Investigations revealed that the misrouting of part of the shipment was due to the actions of station laborers who acted without de la Cruz’s knowledge.
A memorandum by the Superintendent of Transportation supported de la Cruz’s non-negligence and recommended that his suspension be converted into leave with pay.

Claims of Tomas Mendoza, Alfredo Ragas, Nestor Salazar, and Demetrio Agoncillo

In September 1947, during operations at the Caloocan electrical shop and garage of the Luzon Bus Line, discrepancies arose involving company property (a power generator, a box of carpenter tools, and a jeep battery).
The incident occurred when bus No. 39 was driven out of the garage after a diversion maneuver orchestrated by Mendoza, who allegedly distracted the guard by requesting assistance with a noise inspection.
Subsequent investigations by the company, led by General Manager Mr. Sergio Bayan, revealed circumstantial evidence suggesting Mendoza’s connivance with the other employees.
As a result, Mendoza was summarily dismissed on October 27, 1947, while Ragas, Salazar, and Agoncillo were fined modest amounts.
The CIR initially exonerated all four employees on the ground that there was no direct eyewitness testimony of the theft, but the petitioner argued that the thorough internal investigations provided sufficient evidence to uphold the disciplinary measures.

Claims of Eliodoro Bicierro, Irineo Aragon, Fernando Balinguit, and Marcelo Hermosura

On August 3, 1947, a piano arriving at Manila station was received in good condition by Bicierro as the checker, under the supervision of the company’s standard unloading procedures.
During the unloading process, the crate covering the piano was removed and later replaced; however, when the owner reclaimed the piano, damage to parts of it (two legs and a portion of one side) was noted.
An internal investigation determined that only Bicierro was present during the unloading and directly involved in the process leading to the damage, while the other three employees were not connected with the unfolding of events.
The CIR’s findings resulted in Bicierro being held liable with a fine of P100.00, whereas Aragon, Balinguit, and Hermosura had their fines refunded.

Working as auditors for the company, Nodado and Garcia filed claims for overtime pay covering the periods from March 1 to August 15, 1947 (for Nodado) and January 1 to August 15, 1947 (for Garcia).
Their overtime work had been undertaken in response to heavy workloads and under the instruction of a superior, despite a company circular requiring prior approval—a circular that was promulgated after the overtime work was rendered.
The CIR recognized the necessity and validity of the overtime work, ordering the company to pay the appropriate amounts for both auditors.

Felix Basilio, employed as a storekeeper in Baguio under the Benguet Auto Line (a subsidiary of the Manila Railroad Company), rendered overtime work during a period of acute manpower shortage.
His overtime work was not initially recognized by the company; however, approval came from his immediate supervisor and the general management, including a recommendation from the Superintendent.
The CIR upheld the claim, determining that the overtime services rendered were beneficial to the company and deserving of proper compensation.

Santos Umali, a conductor for the Luzon Bus Line, filed a claim for overtime pay, covering work performed during long trips from February 2, 1947, to June 30, 1949.
The company had denied his claim on the basis that the overtime work was rendered without prior authorization as required by Circular No. 251, and due to alleged discrepancies in the timekeeping records.
However, the CIR accepted his submission of corresponding time slips and held that the nature of his duties (which sometimes extended beyond eight hours due to unavoidable delays) justified his overtime compensation.

Several temporary employees who had been engaged on specific projects—such as the rehabilitation of motor cars, trailers, and passenger coaches damaged during the war—demanded permanent appointments after rendering six months of service (twelve for skilled laborers).
The CIR majority opinion granted this demand by directing the company to appoint these workers permanently, regardless of their original temporary project-based assignment.
The company contested this ruling, emphasizing a prior decision (case No. 270-V) wherein a clear distinction was made between employees reassigned to work of a more permanent nature and those remaining on temporary projects.
The appellate review concluded that the prior, more reasonable decision should prevail, thereby reversing the CIR’s order for permanent appointments.

Whether the CIR possessed jurisdiction over claims for the money equivalent of unused vacation and sick leave, traditionally viewed as money claims rather than labor disputes.
Whether the irregularity involving the missing 200 sacks of flour justified the disciplinary suspension of Pedro de la Cruz, and whether his suspension should be treated as leave with pay.
Whether the circumstantial evidence—including internal investigations and managerial reports—was sufficient to uphold the disciplinary measures (dismissal and fines) imposed on Tomas Mendoza and his companions.
Whether liability for the damage to the piano should rest solely with Bicierro, given the timing and nature of the unloading process.
Whether overtime work rendered by auditors, storekeeper, and conductor—performed without prior approval yet under the direction of superior officers—merits compensation, irrespective of technical violations of company circulars.
Whether the CIR’s ruling on the permanent appointment of additional temporary employees was consistent with established case law, particularly in light of the previous decision in case No. 270-V distinguishing between re-assigned and original temporary assignments.