G.R. No. L-21803 December 17, 1966
BAY VIEW HOTEL, INC., petitioner, vs. MANILA HOTEL WORKERS’ UNION-PTGWO, HONORABLES JOSE S. BAUTISTA, ARSENIO I. MARTINEZ, BALTAZAR M. VILLANUEVA and AMANDO C. BUGAYONG, Judges of the Court of Industrial Relations, respondent.

FACTS

On September 27, 1962, the Manila Hotel Workers’ Union-PTGWO filed a petition in the Court of Industrial Relations (CIR) against Bay View Hotel, Inc., operator of the Manila Hotel. The union alleged several grievances: (1) violation of the Eight-Hour Labor Law ( Commonwealth Act No. 444 ) for non-payment of full overtime compensation; (2) violation of the Minimum Wage Law ( Republic Act No. 602 ) for unauthorized monthly deductions of P2.00 for medical fees; (3) failure to refund in full the extra “service charge” collected from customers in lieu of tips to waiters and roomboys; (4) non-compliance with the grant of three days’ vacation leave per year as per the Collective Bargaining Contract; and (5) dismissal of 65 union members, including union officials, without just cause or for union activities, with 41 of them being refused admission through an alleged illegal lockout. The petitioner moved to dismiss the petition on January 16, 1963, arguing that the CIR lacked jurisdiction and that the dismissals and lockout, being unfair labor practice, were the subject of a separate case (Case 3387-ULP). The CIR Judge initially granted the motion to dismiss, but the CIR en banc reversed this order on August 15, 1963, asserting jurisdiction under Commonwealth Act No. 103 and the ruling in the Prisco case, as the complainants exceeded thirty, were still employees, their claims arose from employment relations, and the dispute could cause a strike or lockout. The petitioner then filed this certiorari proceeding.

ISSUE

Whether the Court of Industrial Relations has jurisdiction over the union’s complaint, considering the various claims raised, including those under the Eight-Hour Labor Law, the Minimum Wage Law, and for unfair labor practice, as well as claims for service charge refunds and vacation leave.

RULING

Yes, the Court of Industrial Relations has jurisdiction. The Supreme Court affirmed the CIR en banc resolution. Applying the doctrine restated in Campos vs. Manila Railroad Co., the CIR’s jurisdiction requires: (a) an existing employer-employee relationship or a claim for reinstatement; and (b) a controversy relating to a case certified by the President involving national interest, an unfair labor practice charge, or arising under the Eight-Hour Labor Law or the Minimum Wage Law. Here, an employer-employee relationship existed, and the dismissed employees sought reinstatement, satisfying the first requirement. The claims for overtime pay and unauthorized wage deductions clearly arose under the Eight-Hour Labor Law and the Minimum Wage Law, respectively. The allegation of dismissals and lockout for union activities constituted an unfair labor practice charge. While the claims for service charge refunds and vacation leave, standing alone, might not fall under the CIR’s jurisdiction, they were cognizable by the CIR because they arose from the same employment and were joined with the main claims over which the CIR had jurisdiction. The Court rejected splitting the causes of action between different courts, as it would lead to multiplicity of suits and prejudice the employees. Jurisdiction over the main causes of action placed the entire complaint within the CIR’s jurisdiction. The petition for certiorari was denied, and the CIR en banc resolution was affirmed.