G.R. No. L-20838 - National Shipyards and Steel Corp. vs. Court of Industrial Relations

The National Shipyards and Steel Corporation (NASSCO) is in the business of shipbuilding and repair, operating several vessels including tugboats.
Respondents, consisting of Jose Abiday and 38 other crew members, were employed on these vessels and claimed overtime compensation.

On April 15, 1957, respondents filed a case before the Court of Industrial Relations (CIR), docketed as Case No. 1058-V, seeking overtime pay amounting to P81,093.81.
The case was based on a stipulated statement of facts which included:

Due to the exigencies of service, respondents had to work in excess of eight hours a day and during Sundays and legal holidays, as evidenced by the vessel logbooks, time sheets, and other records.
Respondents were paid only their regular salaries and subsistence allowances with no additional compensation for overtime work.

On November 22, 1957, the CIR ordered NASSCO to pay 25 percent additional compensation for overtime work and directed its examiner to compute the overtime pay based on the submitted records.
The examiner submitted three reports:

The first report, filed on February 14, 1958, covered the period January 1 to December 31, 1957.
The second report, filed on April 30, 1958, covered the period from January 1, 1954 to December 31, 1956.
The examiner credited respondents with an average of five hours of overtime per day in both reports.

In G.R. No. L-13732 (decided April 14, 1959), NASSCO questioned the jurisdiction of the CIR and whether the order directing computation of overtime pay constituted a decision. The petition was dismissed for lack of merit.
In 107 Phil. 1006 (decided April 29, 1960), NASSCO again raised the issue of jurisdiction, which was similarly dismissed.

On November 25, 1960, respondents filed a petition requesting the CIR to direct its examiner to compute overtime pay for the periods 1949-53 and 1958-60, which was granted.
On June 15, 1962, the examiner filed a third report covering these additional periods, which was subsequently approved by the CIR in its order dated November 27, 1962.
NASSCO sought reconsideration before the CIR en banc, but their motion was denied, prompting the petition for review.

NASSCO claimed that there was no evidence supporting the examiner’s finding that respondents rendered an average of five hours of overtime work daily during the periods in question.
They relied on the notion that mere presence on board the vessels did not substantiate a claim for overtime unless it was proven that the employees actually rendered work beyond the regular eight hours, as supported by relevant jurisprudence (e.g., Luzon Stevedoring Co. vs. Luzon Marine Department Union, 101 Phil. 257).

NASSCO argued that the CIR lacked jurisdiction over the claims of three respondents (Rodolfo Riaza, Gualberto Legaspi, and Mauricio Zulueta) who were no longer employees at the time of filing the petition for computation of overtime.
The petitioner maintained that these respondents should not be considered under the ambit of the CIR’s jurisdiction due to their change in employment status.

Pedro de Joya, a marine land surveyor employed by NASSCO, testified that the respondents indeed rendered overtime work, as corroborated by the company’s time sheets, payroll records, logbooks, and other pertinent documents.
His testimony included detailed observations:

The vessel crews were supposed to work on a three-shift system of eight hours each; however, due to limited manpower (with only two men on deck and similar shortages in other departments), each crew member effectively worked at least 12 hours daily.
Special circumstances such as repairs, storms, and other urgent situations often necessitated work schedules exceeding even 12 hours.

Whether there was sufficient evidence to support the examiner’s finding that respondents rendered an average of five hours of overtime on a daily basis during the periods 1949-53 and 1958-60.
Whether the Court of Industrial Relations had jurisdiction over the overtime pay claims of the three respondents who were no longer employees at the time the petition for computation was filed.