G.R. No. L-31890 - People's Homesite and Housing Corp. vs. Court of Industrial Relations

In 1967, during a resettlement initiative in the Sapang Palay area, the Philippine government and the World Food Program (WFP) entered into an agreement to address the housing needs of squatter families by developing the resettlement area.
The People’s Homesite and Housing Corporation (PHHC), a government-created entity later known as the National Housing Authority (NHA), was tasked with implementing a mass housing and resettlement program as provided under Commonwealth Act No. 648.
The PHHC proposed a self-help project to construct two earth dams, roads (850 meters long), drainage channels (17 kilometers), and improvements to 42 kilometers of existing roads.
The project was designed to provide:

Irrigation for over 100 hectares of land.
A reservoir for non-drinking domestic water and fish stocking.
Basic food support through WFP for the participants and their dependents over a period of 560 days.

Application forms titled “WFP Self Help Community Project Information Sheet” were circulated, emphasizing the voluntary nature of the work.
Although participants were initially assigned to work on canals, roads, and drainage projects, the agreed-upon projects with the WFP were never fully implemented.
PHHC ordered its participants to complete a timesheet that became the basis for compensating them a cash incentive of P0.50 per day and a weekly food ration.
Additional arrangements included the provision of work tools and the designation of a PHHC employee as “work supervisor” to manage and inspect the work progress.

The participants, numbering around 700 settlers, expressed dissatisfaction with their work conditions and the meager compensation, prompting them to seek redress by filing a complaint with the Department of Labor.
Following an investigation, Secretary Ople of the Department of Labor sent findings to the PHHC General Manager, highlighting labor law violations and recommending that laborers be paid in accordance with the minimum wage (P6.00 per day at that time).
Subsequent to the departmental findings, PHHC suspended the work on the Sapang Palay project.

The affected participants instituted an action in the Court of Industrial Relations (CIR) against the PHHC, seeking:

Payment of the wage differential (the difference between the minimum wage of P6.00 and the P0.50 actual payment).
Overtime compensation.
Reinstatement of employment.

During trial, the lower court (Court a quo) noted the absence of evidence supporting claims for overtime work and relegated the dispute to a mere money claim, thereby holding that regular courts—not the CIR—had jurisdiction.
On a motion for reconsideration, the CIR en banc reversed the dismissal by ordering the PHHC to pay wage differentials while denying the claims for reinstatement and overtime compensation.
Dissatisfied with this resolution, the PHHC elevated the case to the Supreme Court through a petition for certiorari.

Whether the Court of Industrial Relations (CIR) has jurisdiction over the PHHC, a government-owned and/or controlled corporation that is performing governmental functions.
Whether the CIR exercises jurisdiction in cases where there is no employer-employee relationship between the parties.
Whether the CIR has jurisdiction over pure money claims where reinstatement is not sought.
Whether, given the factual circumstances, an employer-employee relationship can be established between the PHHC and the private respondents (the participating settlers).