G.R. No. 172013 - Halaguena vs. Philippine Airlines, Inc.

On February 20, 1959, the Sampaguita-Vera Perez Workers' Union (PLUM) along with Rafael Barbante and other union members filed a petition with the Court of Industrial Relations against Sampaguita Pictures, Inc.
The petition sought payment of "true and lawful services and compensations" pursuant to the Eight-Hour Labor Law, specifically covering overtime, Sunday work, holiday work, and applicable premiums under Commonwealth Act No. 444.

The petitioners asserted that repeated demands for the payment of overtime services were ignored by the company.
On February 6, 1957, the union submitted several demands to the company, which included claims for overtime pay.
Subsequently, on February 10, 1957, the union served a notice to strike before the Conciliation Service of the Department of Labor, as mandated by law, due to the unheeded demands.

On March 24, 1959, Sampaguita Pictures, Inc. filed a motion to dismiss the petition, contending:

The Court of Industrial Relations lacked jurisdiction because the number of employees interested in the claim was less than thirty-one.
The claim was merely for the collection of overtime pay and compensation, which the company argued was a matter for regular courts.

On October 2, 1959, the Industrial Court ruled that it had jurisdiction to hear the case.

The court based its decision in part on the precedent set in Monares vs. CNS Enterprises, et al., G.R. No. 11749, where it was held that jurisdiction was proper when overtime pay claims were coupled with a prayer for reinstatement.

The company then attempted to have the ruling reconsidered by citing Chua Workers' Union (NLU) vs. City Automotive Company, et al., G.R. No. L-11655, April 29, 1959, which appeared to limit the court’s jurisdiction to cases involving more than just overtime services.
The Industrial Court reaffirmed its jurisdiction, prompting the company to file a petition for certiorari with the Supreme Court, alleging that the industrial court acted beyond its jurisdiction.

The Supreme Court reviewed previous decisions, notably Price Stabilization Corporation vs. Court of Industrial Relations, et al., 108 Phil. 134, which provided critical clarification:

The Court underscored that when the employer-employee relationship exists (or wrongful termination is sought to be remedied via reinstatement), the Industrial Court possesses exclusive jurisdiction over employment-related claims, including those for overtime and similar benefits.

The Court also considered other cases (e.g., Mindanao Bus Employees Labor Union vs. Mindanao Bus Co., and Gomez vs. North Camarines Lumber Co.) but ultimately affirmed the principle outlined in the Price Stabilization Corporation case.
The continued existence of the employment relationship was emphasized by the petitioners’ submission that the dispute over working conditions and wages remained pending, including the notice-to-strike filed with the Conciliation Service.

Whether the Court of Industrial Relations has jurisdiction over claims for overtime pay and compensations, especially when:

The number of employees interested is less than the statutory minimum (thirty-one).
The claim appears to be limited to monetary recovery rather than encompassing broader employment disputes.

Whether the existence (or wrongful termination) of the employer-employee relationship at the time of and after the filing of the petition brings the claim within the industrial court’s purview.
Whether a claim that includes a prayer for reinstatement alters its classification from a mere money claim to an employment dispute.

How the ruling in Monares vs. CNS Enterprises, et al. supports the industrial court’s jurisdiction when claims are coupled with reinstatement.
Whether the contrasting decision in Chua Workers' Union vs. City Automotive Company sufficiently undermines the industrial court’s jurisdiction in this context.
The reconciliation of conflicting past decisions in the context of the present dispute.