Title
Pan American World Airways System vs. Pan American Employees Association
Case
G.R. No. L-16275
Decision Date
Feb 23, 1961
Employees claimed meal periods as overtime; CIR ruled standby meal hours as work time, upheld jurisdiction, and ordered 8-hour shifts inclusive of meal periods.

Case Digest (G.R. No. L-16275)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved:
    • Petitioner: Pan American World Airways System (Philippines)
    • Respondent: Pan American Employees Association
  • Case Background:
    • The case originated from a decision of the Court of Industrial Relations (CIR) in Case No. 1055-V dated October 10, 1959.
    • The CIR ordered the computation of overtime compensation for 14 aircraft mechanics and 2 employees from the Communication Department from February 23, 1952, to July 15, 1958.
    • The CIR also mandated the company to adopt a straight 8-hour shift inclusive of the meal period.
  • Key Allegations:
    • The employees claimed that their one-hour meal period should be considered as overtime work, deducting 15 minutes for eating.
    • The company argued that the meal period was a time of complete rest and not under its control.
  • Collective Bargaining Agreement (CBA):
    • The company contended that the union agreed to withdraw the case in consideration of wage increases outlined in the CBA.
    • The union denied this, stating that the motion to dismiss was based on the understanding that the company would align its work schedule with Commonwealth Act No. 444.
  • Delegation of Judicial Functions:
    • The CIR ordered the Chief of the Examining Division or his representative to compute the overtime compensation, which the company argued was an improper delegation of judicial functions.

Issues:

  • Whether the Court of Industrial Relations had jurisdiction over the claims for overtime compensation.
  • Whether the one-hour meal period should be considered as overtime work.
  • Whether the CIR improperly delegated its judicial functions by ordering the computation of overtime pay by an examiner.
  • Whether there was an agreement to withdraw the case in consideration of wage increases under the CBA.
  • Whether the CIR had the authority to order the company to adopt a straight 8-hour shift inclusive of the meal period.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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