Facts:
PHILIPPINE NATIONAL BANK, petitioner, appealed from the decision of the
Court of Industrial Relations in a certification of an industrial dispute initiated on January 28, 1965, arising from the alleged failure of the bank to organize a Committee on Personnel Affairs as promised in its collective bargaining agreement, and from contested computations of overtime pay. The dispute was temporarily settled by an Industrial Court order of January 28, 1965 creating the Committee on Personnel Affairs and enjoining strikes and lockouts for six months, but on May 22, 1965 the
PHILIPPINE NATIONAL BANK EMPLOYEES ASSOCIATION (PEMA) filed further claims before the Court alleging two causes of action: first, a 1957 bank resolution had revised overtime computation and the bank withdrew related benefits in 1963; and second, after the Supreme Court decision in
National Waterworks and Sewerage Authority vs. NAWASA Consolidated Unions, et al., PEMA demanded that the cost-of-living allowance (equity pay) granted from January 1, 1958, and longevity pay granted from July 1, 1961, be included in the computation of overtime pay. The bank answered that the issues were outside the Court of Industrial Relations’ jurisdiction, were mere money claims, and were premature. The Industrial Court held that it had jurisdiction, found the first cause moot after partial compliance by the bank, and on the second cause ordered that overtime and nighttime rates be computed from January 28, 1962 on the basis of basic salary plus cost-of-living allowance and longevity pay, directed the Court Examiner to compute the amounts, and permitted negotiation as to payment terms because the bank was a government depository; the bank appealed to the Supreme Court, which rendered the present en banc decision on July 30, 1982.
Issues:
Did the
Court of Industrial Relations have jurisdiction to take cognizance of PEMA’s demand to include cost-of-living allowance and longevity pay in the computation of overtime?; Should the
cost-of-living allowance and
longevity pay be included in the computation of overtime pay under
Commonwealth Act 444 and applicable jurisprudence?; Did the Industrial Court commit a grave abuse of discretion or error of law in ordering overtime computation to include those allowances and in its reliance on
National Waterworks and Sewerage Authority vs. NAWASA Consolidated Unions, et al.?
Ruling:
Ratio:
Doctrine: