G.R. No. L-17695 February 26, 1965
ORIENTAL TIN CANS WORKERS’ UNION-PAFLU, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, ORIENTAL TIN CAN AND METAL SHEETS MANUFACTURING COMPANY, ORIENTAL CORRUGATED FIBRE BOARD BOX CORPORATION, ET AL., respondents.

FACTS

The petitioner, Oriental Tin Cans Workers’ Union-PAFLU, filed a petition on March 2, 1959, in the Court of Industrial Relations (CIR) to enforce the observance of the check-off system. The petition alleged that some of its members employed by the respondent companies had signed individual check-off authorizations, and that the union had requested the respondents to check-off the union dues of these members through letters dated February 4 and 24, 1959. The respondents refused to do so. The petitioner claimed such refusal would likely cause a strike. The respondents filed an answer and later a motion to dismiss on the ground that the CIR had no jurisdiction over the subject matter. After hearing, the CIR Judge issued an order dismissing the petition. The petitioner’s motion for reconsideration was denied by the CIR en banc. The petitioner then filed a petition for certiorari with the Supreme Court to review the CIR’s order and resolution.

ISSUE

Whether jurisdiction to enforce check-off authorized by employees in writing pertains to the Court of Industrial Relations.

RULING

No. The Supreme Court affirmed the order and resolution of the Court of Industrial Relations dismissing the petition. The Court held that under Republic Act No. 875 , the CIR’s jurisdiction has been curtailed. For the CIR to have jurisdiction over a controversy, the circumstances outlined in Campos vs. Manila Railroad Company must be present: (a) an employer-employee relationship exists or the claimant seeks reinstatement; and (b) the controversy relates to a case certified by the President as involving national interest, has a bearing on an unfair labor practice charge, or arises under the Eight-Hour Labor Law or the Minimum Wage Law. The petitioner contended the controversy arose under Section 10 of the Minimum Wage Law ( Republic Act No. 602 ), which recognizes the right to check-off when authorized in writing by employees. However, the Court ruled that not every case arising under the Minimum Wage Law falls within the CIR’s jurisdiction. Under Section 16 of Republic Act No. 602 , the CIR has jurisdiction only in two instances: (1) when the dispute involves minimum wages above the applicable statutory minimum, or (2) where the demands for minimum wages involve an actual strike. The present case involved neither a dispute over minimum wages above the statutory minimum nor an actual strike. Therefore, the CIR correctly dismissed the petition for lack of jurisdiction.