GR L 2261; (June, 1949) (Digest)
G.R. No. L-2261; June 16, 1949
PAMPANGA BUS COMPANY, INC., petitioner, vs. EMPLOYEES ASSOCIATION OF THE PAMPANGA BUS COMPANY, INC., and THE COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The petitioner, Pampanga Bus Company, Inc., owned buses and trucks which, along with their drivers and conductors, were taken over by the United States Army for war purposes starting December 8, 1941. The drivers and conductors rendered service to the U.S. Army from January 1, 1942, without receiving salaries, except for two drivers. After the war, the company received compensation from the U.S. Army totaling P875,468.12 for the value and rental of the vehicles and accessories. The Employees Association filed a claim with the Court of Industrial Relations (CIR), seeking a 20% share of this amount for the employees. The CIR denied the claim for a percentage share but awarded the drivers compensation equivalent to three months’ salary based on their December 1941 pay, excluding the conductors. The company challenged this award via certiorari.
ISSUE
Whether the Court of Industrial Relations acted with grave abuse of discretion in awarding the drivers three months’ salary as compensation for their services to the U.S. Army, despite the drivers not specifically praying for such relief.
RULING
No. The Supreme Court upheld the CIR’s decision. The taking of the company’s vehicles by the U.S. Army did not transfer ownership but only the right of use, as evidenced by the subsequent payment of rentals to the company. The drivers continued to be employees of the company, which induced them to serve the Army with promises of payment. The services rendered created an implied contract (quantum meruit) obligating the company to pay reasonable compensation. The CIR, acting within its broad discretion as an arbitral body in labor disputes, was not strictly bound by the specific relief prayed for and could award what was just and equitable under the circumstances. The award of three months’ salary was a reasonable valuation of the services. The petition was dismissed.
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