G.R. No. L-17750 - A. L. Ammen Transportation Co., Inc. vs. Borja

Case Citation: 116 Phil. 242 [G.R. No. L-17750. August 31, 1962]
Parties: A. L. Ammen Transportation Company Inc. and Consolidated Auto Lines, Inc. (Petitioners) vs. Jose Borja (Respondent)
Nature of Appeal: Appeal by certiorari from an Order of the Court of Industrial Relations.

Employment Details: Jose Borja was employed as Supervising Inspector from January 1, 1952, to March 10, 1957, with a basic salary of P180.00, daily per diems of P3.00, and a monthly bonus of P30.00.
Initial Claim: On April 15, 1958, Borja filed an action for overtime compensation and damages in the Court of First Instance of Albay (Civil Case No. 1905).
Subsequent Proceedings: Following the dismissal of his claim with the Department of Labor, Borja initiated proceedings in the Court of Industrial Relations.

Findings: The Court ordered the respondents to pay Borja for services rendered beyond eight hours a day from January 1, 1952, to March 10, 1957.
Compensation Calculation:
- A Chief Examiner was appointed to compute the exact amount owed, based on inspection records.
- A 30-minute lunch break will be deducted from the total hours.
- Sundays and holidays worked will not be considered compensable overtime.

Prescription: Petitioners argued that Borja’s claim had prescribed as it was filed more than three years after the cause of action accrued.
- Legal Reference: Cited Republic Act 1994, which mandates actions under Commonwealth Act No. 444 must be commenced within three years.
Jurisdiction: Claimed the Court of Industrial Relations lacked jurisdiction as Borja's primary claim was for overtime wages.
Company Memorandum: Asserted the validity of a company directive prohibiting work beyond eight hours.

On Prescription:
- The Court found Borja's action commenced before the effective date of Republic Act No. 1994, thus exempting it from the three-year prescription period.
- Borja’s claim was initiated with the Department of Labor on May 29, 1957.
On Jurisdiction:
- The Court ruled that because Borja also sought reinstatement, the case fell within its jurisdiction beyond just claiming overtime wages.
On Company Memorandum:
- The Court concluded that sufficient evidence indicated Borja had received verbal instructions to work overtime despite the memorandum.

Labor Rights: The Court emphasized the liberal interpretation of labor laws in favor of employees (Article 1702, New Civil Code).
Jurisdiction of the Court of Industrial Relations: Extends to claims involving employment reinstatement and wage disputes.