Title
A. L. Ammen Transportation Co., Inc. vs. Borja
Case
G.R. No. L-17750
Decision Date
Aug 31, 1962
Jose Borja sued for overtime pay after dismissal; Court of Industrial Relations ruled in his favor, affirming jurisdiction, no prescription, and overtime approval despite company memo.
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Case Summary (G.R. No. L-17750)

Case Overview

  • 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.

Background

  • 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.

Court of Industrial Relations Order

  • 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.

Legal Arguments of Petitioners

  • 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.

Court's Rulings

  • 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.

Key Legal Principles

  • 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.

Key Takeaways

  • The Court upheld the ruling of the Court of Industrial Relations, affirming Borja's right to claim compensation for overtime work.
  • The decision highlighted the im
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