G.R. No. L-1206; October 30, 1947

Manila Electric Company, petitioner, vs. Public Utilities Employees’ Association, respondent.

FACTS

The Court of Industrial Relations ordered the Manila Electric Company (Meralco) to pay a 50% increase for work done on Sundays and legal holidays. Meralco appealed, arguing this decision violated Commonwealth Act No. 444 , Section 4, which exempts public utilities (like those supplying electricity or transportation) from the obligation to pay extra compensation for work on Sundays and holidays.

ISSUE

Whether the Court of Industrial Relations had the authority to order a public utility to pay extra compensation for work on Sundays and legal holidays, despite the exemption in Commonwealth Act No. 444 .

RULING

No. The Supreme Court reversed the decision of the Court of Industrial Relations. Section 4 of Commonwealth Act No. 444 clearly exempts public utilities performing essential public services (like supplying electricity or providing transportation) from the requirement to pay extra compensation when compelling employees to work on Sundays and legal holidays. This exemption is a reasonable classification and not class legislation. The general powers of the Court of Industrial Relations under Commonwealth Act No. 103 are restricted by this specific subsequent law. Therefore, Meralco, as a public utility, is not obligated to pay the additional compensation ordered by the lower court.