Title
Bay View Hotel, Inc. vs. Manila Hotel Workers' Union-PTGWO
Case
G.R. No. L-21803
Decision Date
Dec 17, 1966
Bay View Hotel faced union grievances over unpaid overtime, illegal deductions, service charge refunds, denied vacation leave, and unfair labor practices, including dismissals and lockouts. The CIR asserted jurisdiction, upheld by the Supreme Court, to resolve all claims under labor laws, avoiding split jurisdiction and ensuring efficient dispute resolution.

Case Summary (G.R. No. L-21803)

Background of the Dispute and Allegations

The Manila Hotel Workers’ Union filed grievances on September 27, 1962, against Bay View Hotel, Inc. The union alleged several violations: (1) non-payment of full overtime compensation for work beyond eight hours daily and on Sundays and holidays, breaching Commonwealth Act No. 444; (2) unauthorized salary deductions of P2.00 per month for medical fees, contravening Sections 10(f) and (g) of Republic Act No. 602; (3) withholding full refund or payment of the official “service charge” collected from customers, which was meant as tips; (4) non-compliance with granting the stipulated three days of annual vacation leave as per the Collective Bargaining Contract; and (5) unfair labor practices consisting of the illegal dismissal of 65 union members, including union officers, and the exclusion of 41 employees following purported illegal lockouts in August and September 1962.

Procedural History and Jurisdictional Question

Bay View Hotel moved to dismiss the complaint in January 1963, arguing lack of jurisdiction by CIR and that the allegations of dismissal and lockout were already before another CIR branch as an unfair labor practice (ULP) case. The CIR initially dismissed the petition for want of jurisdiction, but the en banc reversed that order in August 1963, asserting jurisdiction citing Commonwealth Act No. 103 and the precedent in Prisco vs. CIR. The en banc emphasized that since the number of complainants exceeded thirty, the employees were still employed, and the claims arose from the employment relationship potentially leading to strike or lockout, CIR had jurisdiction.

Supreme Court Doctrine on CIR Jurisdiction

The Supreme Court’s jurisdictional framework, grounded in the 1956 PAFLU vs. Tan decision and further clarified in Prisco vs. CIR (1960), Sy Huan vs. Bautista (1961), and Campos vs. Manila Railroad (1962), delineates CIR jurisdiction to:

  1. Labor disputes affecting industries certified by the President as indispensable to national interest (per Republic Act No. 875);
  2. Minimum wage controversies under Republic Act No. 602;
  3. Hours of employment disputes under the Eight-Hour Labor Law (Commonwealth Act No. 444); and
  4. Unfair labor practice claims under Section 5(a), Republic Act No. 875.

However, such jurisdiction is conditioned upon the continuing existence of the employer-employee relationship or a claim for reinstatement by the employee. Once the employment relationship terminates and reinstatement is not sought, claims transform into mere money claims falling outside CIR jurisdiction and within the competence of regular courts.

Application of Jurisdictional Principles to the Instant Case

The Court found that the employer-employee relationship between Bay View Hotel and the union members persisted or was sought to be re-established through reinstatement claims, thus satisfying the initial requirement for CIR jurisdiction. The complainants’ claims regarding unpaid overtime fall squarely under the Eight-Hour Law, while the unauthorized salary deductions violate the Minimum Wage Law. The allegations of illegal dismissal and lockout constitute unfair labor practice charges, indisputably within CIR jurisdiction.

Concurrent Jurisdiction and Case Consolidation

Although the union admitted that the dismissal and lockout were subject to investigation under a separate ULP case (No. 3387-ULP) before another CIR branch, this procedural overlap did not divest CIR of its jurisdiction. The Court emphasized that the complaint was filed prior to the admission and investigation of the ULP case, and the issues were inextricably interconnected such that jurisdiction, once acquired, is retained to prevent piecemeal litigation.

Two additional grievances—non-payment of the “service charge” and failure to grant vacation leave—were not explicitly categorized as within CIR’s jurisdiction by themselves. Yet, given their connection to the main claims, CIR’s jurisdiction extended to the entire complaint to promote comprehensive resolution of employment-related disputes arising from the same relationship.

Rationale Against Piecemeal Litigation in Labor Disputes

The Court refused to fragment jurisdictional authority over separate claims arising from the employment relation

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