G.R. No. 24314 September 28, 1970
MANILA HOTEL COMPANY, petitioner, vs. PINES HOTEL EMPLOYEES ASSOCIATION and COURT OF INDUSTRIAL RELATIONS.

FACTS

The respondent Pines Hotel Employees Association (PHEA) filed a petition with the Court of Industrial Relations (CIR) on July 22, 1963, seeking an order for the petitioner Manila Hotel Company (MHC) to pay its members the benefits due under Republic Act 1880 (the 40-Hour Week Law) from July 1, 1957. The MHC opposed, claiming the demand was settled by a “Settlement of Grievance” agreement dated February 9, 1962, a supplement to their Collective Bargaining Agreement. This agreement stated that “regular extras” who rendered continuous service for six months or more and were in service on July 1, 1957, would be given automatic salary increases under R.A. 1880. A CIR examiner’s report dated March 23, 1964, covering July 1, 1957 to December 31, 1963, found eight MHC employees were still being paid pre-July 1, 1957 wages, with a total differential of P8,795.62 due. The MHC objected, arguing these employees did not qualify under the agreement because they had not served at least six months prior to July 1, 1957. The PHEA countered that the six-month period referred to the time prior to the agreement’s date (February 9, 1962), not July 1, 1957. The CIR, in its Order of December 22, 1964, ruled in favor of the PHEA, interpreting that the six-month service requirement applied only to extra employees taken in after July 1, 1957, and that the eight named employees were entitled to differential pay. The MHC’s motion for reconsideration, which also challenged the CIR’s jurisdiction and argued the PHEA had waived the benefits, was denied on February 24, 1965.

ISSUE

1. Whether the Court of Industrial Relations had jurisdiction over the petition filed by the PHEA.
2. Whether the PHEA, through the “Settlement of Grievance” agreement, validly waived the benefits under R.A. 1880 for its members.

RULING

1. Yes, the CIR had jurisdiction. The issue of benefits under R.A. 1880 was intertwined with union interest, as recognized by the MHC’s own agreement with the PHEA. The petition presented a conflict in the interpretation of the agreement regarding compliance with the law, which could disclose an unfair labor practice, a matter within the CIR’s competence under Section 5(a) of R.A. 875 (the Industrial Peace Act). Furthermore, R.A. 1880 resembles the Eight-Hour Labor Law (C.A. 444), and claims arising from employment under such laws, where an employer-employee relationship exists, are within the jurisdictional competence of the CIR.
2. No, the PHEA did not validly waive the benefits. R.A. 1880 is a mandatory enactment for the benefit of the laboring masses, providing for automatic salary increases to prevent a reduction in pay due to reduced work hours. The Court has a duty to apply the full import of the law, recognizing the disadvantaged bargaining status of employees who might be apprehensive in asserting claims. The CIR’s interpretation of the agreement was upheld, and the waiver contention was deemed devoid of merit.
Accordingly, the CIR’s Order dated December 22, 1964 and Resolution dated February 24, 1965 were affirmed.