Case Summary (G.R. No. L-16275)
Petitioner’s Principal Contentions
Petitioner advanced five propositions: (1) the Industrial Court lacked jurisdiction to order payment of overtime (a monetary claim for regular courts); (2) the finding that the one-hour meal period constituted overtime work (after deducting 15 minutes) lacked substantial evidence; (3) the Industrial Court improperly delegated judicial functions by ordering the Chief of the Examining Division to compute overtime; (4) there was no substantial evidence to reject petitioner’s claim that Case No. 1055-V had been withdrawn in consideration of wage increases in the Collective Bargaining Agreement (Exh. “A”); and (5) the Industrial Court had no authority to order permanent adoption of a straight 8-hour shift inclusive of the meal period.
Key Dates and Procedural Posture
The appealed decision is the Court of Industrial Relations’ resolution in Case No. 1055V (dated October 10, 1959) and its denial of petitioner’s motion for reconsideration. The Industrial Court’s dispositive order commanded computation of overtime for 14 aircraft mechanics and two employees from the Communication Department for the period February 23, 1952 through July 15, 1958; it required company cooperation and appointment of two company and two union representatives to assist the Court Examiner; and it ordered permanent adoption of a straight 8-hour shift inclusive of the meal period.
Applicable Constitution and Legal Context
Applicable constitutional framework: 1935 Philippine Constitution. The Court’s jurisdictional analysis relied on established precedents permitting the Industrial Court to entertain overtime claims when complainants remained in the employer’s service at the time of filing or sought reinstatement, distinguishing such claims from ordinary monetary actions reserved to regular courts when those conditions are not met.
Industrial Court’s Dispositive Order (as quoted)
The Industrial Court ordered the Chief of the Examining Division or his representative to compute overtime compensation due the identified employees for the specified period and to report within 30 days; directed the company to present time sheets and other necessary documents; required two representatives each from company and union to assist the Court Examiner; and ordered the company to permanently adopt a straight 8-hour shift inclusive of the meal period.
Supreme Court — Jurisdictional Holding
The Supreme Court affirmed the Industrial Court’s jurisdiction. Citing prior decisions (e.g., NASSCO v. CIR; PRISCO v. CIR; Board of Liquidators v. CIR; Sta. Cecilia Sawmills Co. v. CIR; Ajax-International Corp. v. Seguritan; Sampaguita Pictures, Inc. v. CIR), the Court held that the Industrial Court may properly take cognizance of overtime claims where the complainants were still in the employer’s service when the petition was filed. In this case, there was no dispute that the employees claiming overtime were still employed when the case was filed and apparently remained with the company thereafter, so jurisdiction could not be assailed.
Supreme Court — Meal Period Characterization and Evidentiary Findings
The Supreme Court upheld the Industrial Court’s factual finding that the one-hour meal period was not a period of complete rest but a working hour because mechanics were required to stand by for emergency work, faced reprimand if unavailable when called, and were on occasion summoned from meals or hurried to finish eating to perform work. The Court found these factual findings supported by the record and thus sustained the Industrial Court’s conclusion that the meal period (minus a 15-minute eating allowance) constituted compensable overtime.
Supreme Court — Collective Bargaining Agreement and Alleged Withdrawal
Regarding petitioner’s contention that the union agreed to withdraw Case No. 1055-V in consideration of wage increases in the Collective Bargaining Agreement (Exh. “A”), the Supreme Court found substantial evidence supporting the Industrial Court’s determination that no such agreement existed. The Court reasoned that such an understanding would have been incorporated into the contract if it had existed. The union’s motion to dismiss without prejudice, filed after the contract’s signing, was expressly conditioned on the company formulating a work schedule consistent with Civil Aeronautics (C. A.) 444 and did not establish that the case had been withdrawn in consideration of wage increases.
Supreme Court — Delegation of Computation
The Supreme Court rejected the claim that ordering the Chief of the Examining Division (or hi
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Procedural History
- Appeal by certiorari to the Supreme Court from the decision of the Court of Industrial Relations in Case No. 1055V dated October 10, 1959, and from the en banc resolution denying the petitioner's motion for reconsideration.
- The appealed decision contained a dispositive portion ordering computations of overtime compensation, adoption of a straight 8-hour shift inclusive of meal period, and participation of company and union representatives in the computation process.
- The Supreme Court reviewed five propositions advanced by the petitioner attacking jurisdiction, factual findings, alleged improper delegation, alleged agreement to withdraw the case, and the authority to order shift adoption.
Parties and Subject Matter
- Petitioner: Pan American World Airways System (Philippines).
- Respondent: Pan American Employees Association.
- Subject matter: Claim for overtime compensation by certain employees (fourteen aircraft mechanics and two employees from the Communication Department) and a Court order requiring the company to adopt a straight 8-hour shift inclusive of the meal period.
Dispositive Portion of the Court of Industrial Relations' Decision (as quoted in the record)
- "Wherefore, the Court orders the Chief of the Examining Division or his representative to compute the overtime compensation duo the aforesaid fourteen (14) aircraft mechanics and the two employees from the Communication Department, based on the time sheet of said employees from February 23, 1952 up to the including July 15, 1958 and to submit his report within 30 days for further disposition by the Court; and the company shall show to the Court Examiner such time sheets and other documents that may be necessary in the aforesaid computation; and two (2) representatives for the company and two (2) representatives for the union shall be chosen to help the Court Examiner in said computation."
- "The company is also ordered to permanently adopt the straight 8-hour shift inclusive of meal period which is mutually beneficial to the parties."
- "SO ORDERED."
Issues Presented on Appeal (Petitioner's Five Propositions)
- (1) The Industrial Court has no jurisdiction to order the payment of overtime compensation, such being a mere monetary claim cognizable by regular courts.
- (2) The finding that the one-hour meal period should be considered overtime work (after deducting 15 minutes as time allotted for eating) is not supported by substantial evidence.
- (3) The Court below had no authority to delegate its judicial functions by ordering the Chief of the Examining Division or his representative to compute the overtime pay.
- (4) The finding that there was no agreement to withdraw Case No. 1055-V in consideration of the wage increases in the Collective Bargaining Contract (Exh. "A") is not supported by substantial evidence.
- (5) The Court below had no authority to order the Company to adopt a straight 8-hour shift inclusive of meal period.
Jurisdictional Determination and Precedents Cited
- The Supreme Court stated the controlling rule: the Industrial Court may properly take cognizance of overtime pay cases if, at the time of the petition, the complainants were still in the service of the employer, or, having been separated, should ask for reinstatement; otherwise such claims should be brought before the regular courts.
- Prior decisions cited in support of this rule (as referenced in the opinion): NASSCO vs. CIR, et al., 107 Phil. 1006; PRISCO vs. CIR, et al., 102 Phil. 515; Board of Liquidators, et al., vs. CIR, et al., 108 Phil. 162; Sta. Cecil