Case Summary (G.R. No. L-16223-25)
Applicability of Law and Background of the Dispute
The plaintiffs filed claims for unpaid overtime compensation after their demands to the NARIC went unheeded. On July 15, 1954, the plaintiffs sought recourse through the Wage Administration Service, which rendered decisions in their favor on February 16, 1955. In response, NARIC refused to comply with the order, leading to the plaintiffs filing separate actions that were jointly heard by the Court of First Instance of Manila.
Evidence of Overtime Work
The plaintiffs proved that they rendered overtime work by providing testimonies from themselves and the officers-in-charge at their respective NARIC agencies, along with certified time records. These records, although some were destroyed, largely supported their claims. The plaintiffs asserted that their overtime work was mandated by the necessity of safeguarding NARIC's properties and due to management's refusal to authorize additional guards.
NARIC's Defense
NARIC's defenses included a policy asserted by its President-Manager that restricted payment for overtime unless pre-approved, a contention based on a Board of Directors' resolution. NARIC also pointed to an existing claim by the NARIC Workers' Union, which claimed benefits for overtime work under the jurisdiction of the Court of Industrial Relations, arguing that it encompassed the plaintiffs’ cases. They additionally contested the applicability of the Eight Hour Labor Law and argued against including the period of the plaintiffs' leave of absence in the overtime compensation calculations.
Court's Ruling on Approval of Overtime
The court rejected NARIC's claims regarding the necessity of prior approval for overtime work, referencing Commonwealth Act No. 444, which affirms that any agreement contravening the Act is null and void. This reinforced the notion that overtime performed under necessity should be compensated regardless of the management’s pre-approval policies.
Court's Jurisdiction and the Union's Petition
The court concluded that the petition filed by the NARIC Workers' Union, which sought to extend benefits to province employees, was irrelevant to the plaintiffs as they were no longer employed by NARIC at the time of the filing. The claims made prior to the union petition were affirmatively filed with the Wage Administration Service, showing the plaintiffs' initiatives were distinct and separate.
Rejection of Applicability of the Eight Hour Labor Law
The court also deemed the argument that the Eight Hour Labor Law was not applicable to NARIC unpersuasive. Past rulings clarified that government-owned corporations, including NARIC, are not exempt from labor regulations concerning hours and overtime, thereby substantiating the plaintiffs’ entitlement to supplemental compensa
...continue readingCase Syllabus (G.R. No. L-16223-25)
Case Overview
- The case involves an appeal by the National Rice and Corn Corporation (NARIC) following a decision rendered by the Court of First Instance of Manila concerning three separate but related cases.
- The plaintiffs, Fermin Reotan, Silvestre Reotan, and Praxedes Balane, were employees of NARIC, serving as guards-watchmen in different branches and claiming unpaid overtime compensation for their services.
Background of the Case
- Plaintiffs' Employment:
- Fermin Reotan: Employed from December 1, 1946, to March 31, 1954.
- Silvestre Reotan: Employed from July 12, 1949, to February 12, 1954.
- Praxedes Balane: Employed from September 12, 1949, to March 31, 1952.
- Work Conditions:
- Each branch had only two guards-watchmen, necessitating 12-hour shifts to ensure coverage, except during vacations or sick leaves.
Claims for Overtime Compensation
- On July 15, 1954, after unsuccessful demands for overtime compensation, the plaintiffs filed claims with the Wage Administration Service.
- The Wage Administration Service ruled in favor of the plaintiffs on February 16, 1955.
- Despite this ruling, NARIC continued to refuse payment, prompting the plaintiffs to file separate legal actions.
Evidence Presented
- Testimonies from both plaintiffs and officers-in-charge confirmed the overtime work.
- Time-records, many of which were certified as accurate, were presented as evidence.
- Some records were destroyed by termites, limiting the evidence available.
NARIC's Arguments Against Payment
- NARIC contended that:
- Overtime work wa