G.R. No. L-12300 - Potente vs. Saulog Transit, Inc.

On October 15, 1954, Venancio Potente, a former bus inspector of Saulog Transit Incorporated, filed a complaint with the Wage Administration Service (WAS) seeking unpaid overtime compensation, unjust dismissal benefits, and vacation and sick leave pay.
The claim specifically sought payment of P8,359.75 for unpaid overtime compensation, in addition to one month’s salary of P210.00, purportedly as compensation for his alleged indirect dismissal.

On March 10, 1955, a WAS investigator recommended that Potente was entitled to the amount claimed, effectively rendering a “decision” awarding him P8,359.75 for unpaid overtime (with the aggregate including the salary for dismissal).
This recommendation was subsequently approved by the Acting Chief of the Wage Protection Division and the Acting Chief of WAS.
The decision by the WAS was treated as final and executory within its administrative process, as no appeal was taken from it.

Over a year after the WAS decision, Potente initiated a petition with the Court of First Instance of Rizal, asserting that the WAS decision had become final and executory.
Without prior notice to the employer or conducting a hearing, the court issued an order on October 25, 1956, directing the issuance of a writ of execution against Saulog Transit Inc. to recover the sum of P8,359.75.
The employer, upon receipt of the order and the writ, filed a petition to set aside the writ, which was denied on January 18, 1957.
Subsequently, on petition of Potente, the lower court ordered the issuance of an alias writ of execution on February 8, 1957.

The employer objected to the court’s procedure of enforcing the WAS “decision” directly via a writ of execution, claiming that such enforcement bypassed the requirement of an ordinary judicial action.
Neither the lower court nor counsel relied upon any legal provision authorizing direct execution of a WAS decision without a full court trial on the merits and a corresponding judgment.

Whether an administrative “decision” rendered by the Wage Administration Service, granting Potente the award of unpaid overtime compensation, may be directly executed by a court without a prior ordinary suit for money recovery.
Whether the procedural mechanism employed—i.e., issuance of a writ of execution based solely on the WAS decision—fits within the definition of “an action” under the Rules of Court and statutory laws governing wage claims and labor disputes.
Whether existing statutes (specifically sections 15(d), 15(e), and 16(a) of Act 602, among others) authorize the enforcement of unpaid wage claims through direct execution of an administrative decision, as opposed to requiring the filing of an ordinary court action.