GR L 22979; (January, 1967) (Digest)
G.R. No. L-22979 January 27, 1967
RHEEM OF THE PHILIPPINES, INC and GORDON W. MACKAY, petitioners, vs. ZOILO R. FERRER, MARIO TATLONGHARI, SANTO MARILAG and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
Petitioners Rheem of the Philippines, Inc. and Gordon W. Mackay challenge the jurisdiction of the Court of Industrial Relations (CIR) via certiorari and prohibition. The challenge arises from the CIR’s denial of petitioners’ motion to dismiss a complaint filed by the principal respondents (Ferrer, Tatlonghari, and Marilag). The complaint seeks: 1) reinstatement with back wages due to alleged illegal dismissal; 2) moral and exemplary damages; 3) payment of salary increase and separation pay; 4) night differential pay; and 5) premium pay for work on Sundays and legal holidays. The petitioners’ motion to dismiss was grounded on the CIR’s alleged lack of jurisdiction over the subject matter.
ISSUE
Whether the Court of Industrial Relations has jurisdiction to hear and determine the complaint filed by the respondents, which includes claims for reinstatement, back wages, damages, salary increases, separation pay, night differentials, and premium pay for Sunday and holiday work.
RULING
The Supreme Court ruled that the Court of Industrial Relations has jurisdiction over all the claims in the complaint.
1. On the claim for premium pay for work on Sundays and legal holidays: The Court held that the right to such pay is guaranteed by the Eight-Hour Labor Law. Since the respondents seek reinstatement, the case falls within the rule established in Campos vs. Manila Railroad Co., which requires for CIR jurisdiction that an employer-employee relationship exists or reinstatement is sought, and the controversy arises under laws like the Eight-Hour Labor Law.
2. On the claim for night differentials: The Court, citing Philippine Engineers’ Syndicate, Inc. vs. Bautista, held that the CIR retains jurisdiction over claims for additional compensation for night work. The Court rejected the argument that Republic Act 875 removed such jurisdiction, noting its previous rulings upholding the CIR’s authority to adjudicate claims for night differential pay.
3. On the other claims (reinstatement, back wages, damages, salary increases, and separation pay): The Court held that these matters arose out of the same employment and, since an employer-employee relationship is sought to be re-established, the CIR “has jurisdiction over all claims arising out of, or in connection with, employment.” Furthermore, to avoid multiplicity of suits and ensure orderly administration of justice, all causes of action should be heard by a single court—the CIR—especially since the claims for Sunday/holiday pay and night differentials are already within its jurisdiction.
The petition for certiorari and prohibition was dismissed.