G.R. No. L-34116 November 24, 1988
NATIONAL WATERWORKS AND SEWERAGE AUTHORITY, petitioner, vs. NWSA CONSOLIDATED UNION, MARCIAL ESPLANA and THE COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

Marcial Esplana, a toolkeeper for the National Waterworks and Sewerage Authority (NWSA), previously won a claim for overtime compensation from January 1957 to October 1963, which NWSA paid. While that case was pending, Esplana filed a new petition seeking additional compensation for similar overtime, nighttime, and holiday work performed from November 1, 1963, to September 26, 1968. The Court of Industrial Relations (CIR) granted the petition and directed a court examiner to compute the differentials, resulting in a total claim of P47,019.45.
NWSA objected to the examiner’s report on several grounds, primarily arguing that the overtime services were not duly authorized in writing by the NWSA General Manager as required. The CIR, after review, made corrections to the computations and approved differentials totaling P42,274.10, ordering NWSA to deposit this amount. NWSA appealed, contesting the authorization and the applicable premium rates.

ISSUE

The primary issues were: (1) whether Esplana’s overtime, nighttime, and holiday work were duly authorized in writing, and (2) whether overtime work performed on Saturdays, Sundays, and legal holidays beyond eight hours was entitled to a 50% premium.

RULING

The Supreme Court affirmed the CIR’s decision. On the issue of authorization, the Court found substantial evidence supporting the CIR’s factual finding that Esplana’s extra work was authorized. Esplana testified, without contradiction from NWSA, that due to the nature of his work—issuing and receiving tools for multiple work gangs operating at different hours—he had written monthly authorizations from his chief, which were submitted to the NWSA Auditor. Although the Auditor’s office produced only one sample authorization, the CIR correctly relied on other evidence like time cards and salary index cards to verify the hours worked and compute the differentials.
Regarding the premium rate, the Court upheld the 50% premium for work on Sundays and legal holidays that also exceeded regular working hours. This was based on the Collective Bargaining Agreement (CBA), which provided a 25% premium for work on such days and an additional 25% for overtime exceeding regular hours, totaling 50%. Evidence, including testimony from an NWSA auditing officer, confirmed that NWSA itself had been paying this 50% premium since 1966. The Supreme Court emphasized that the CIR’s factual findings, being supported by substantial evidence, are conclusive. It found no grave abuse of discretion in the CIR’s adjusted computations or its legal conclusions, thereby dismissing NWSA’s petition.