Case Summary (G.R. No. L-31890)
Decision Overview
The petition for certiorari filed by the PHHC seeks to reverse a prior resolution by the Court of Industrial Relations (CIR) that ordered PHHC to pay wage differentials to the private respondents for work conducted between July 25, 1967, and February 1968. In essence, the matter concerns whether the PHHC, a government-owned corporation, falls under the jurisdiction of the CIR, which concerns the legality of the orders pertaining to wage claims.
Applicable Law
This case is decided under the framework of the 1987 Philippine Constitution, particularly regarding labor relations and protections. Key pieces of legislation cited include Commonwealth Act No. 103, which outlines the powers of the CIR.
Jurisdiction and Government Functions
A pivotal argument raised by the PHHC is that it was performing governmental functions and therefore exempt from the jurisdiction of the CIR. The Court discussed prior rulings that clarify the distinction between governmental and proprietary functions of government agencies. Establishing this distinction is critical since the CIR has jurisdiction over disputes involving corporations performing proprietary functions but not over those engaged in governmental operations.
Historical Agency Context
The PHHC, established in 1941, is a successor to the National Housing Commission (NHC) and has been charged with executing governmental housing and resettlement policies in the Philippines. This historical context illustrates the nature of the PHHC’s operations and how they align more closely with governmental functions than with proprietary functions.
Findings on Employment Relationship
While the PHHC contended that there was no employer-employee relationship, the ruling considered the factual circumstances of the workers’ engagements and the nature of their work under the PHHC. The Court examined evidence that suggested that the participants were acting under the authority of PHHC, further scrutinizing workplace conditions, wage payments, and expectations of work that indicated an employment relationship.
Court's Conclusion
The Supreme Court ultimately upheld that the CIR lacked jurisdiction over disputes involving the PHHC due to its nature as a governmental entity executing fundamental state functions related to housing and urban development. Therefore, the earlier CIR ruling mandating wage differentials was set aside. The decision re-confirmed that entities performing governmental functions are subj
Case Syllabus (G.R. No. L-31890)
Case Background
- The case involves the People's Homesite and Housing Corporation (PHHC) petitioning for certiorari against the Court of Industrial Relations (CIR) regarding a resolution ordering the PHHC to pay wage differentials to private respondents for work done between July 25, 1967, and February 1968.
- The petition arises from a government agreement with the World Food Program (WFP) aimed at providing employment and food support to squatter families in the Sapang Palay resettlement area through a self-help project.
- The project included the construction of earth dams, roads, and irrigation channels, with the aim of improving food production and living conditions for the residents.
Nature of Employment and Compensation
- Participants in the project were recruited voluntarily and were to receive a cash incentive of P0.50 per day, along with a weekly food ration.
- The PHHC provided tools and equipment for the work, and a supervisor managed the operations.
- Complaints emerged regarding inadequate compensation compared to the minimum wage, prompting the participants to seek intervention from the Department of Labor.
Legal Proceedings
- The Secretary of Labor found violations of labor laws and suggested that the lab