GR 35254; (January, 1973) (Digest)
G.R. No. L-35254 January 29, 1973
THE PHILIPPINE AMERICAN MANAGEMENT COMPANY, and PHILIPPINE AMERICAN LIFE INSURANCE COMPANY, petitioners, vs. THE PHILIPPINE AMERICAN MANAGEMENT EMPLOYEES ASSOCIATION (PAMEA-FFW) and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
A labor dispute concerning minimum wage issues arose between the Philippine American Management Company (PAMCI) and the Philippine American Management Employees Association (PAMEA-FFW). After conciliation efforts failed, the Secretary of Labor, acting under Section 16(c) of the Minimum Wage Law ( Republic Act No. 602 ), endorsed the dispute to the Court of Industrial Relations (CIR) pursuant to a presidential directive. PAMCI filed an urgent motion to dismiss, contesting the CIR’s jurisdiction by arguing the dispute did not genuinely involve a minimum wage demand. The CIR deferred resolution on this motion. Subsequently, the union filed an urgent motion for a return-to-work order, which the CIR granted on April 19, 1972, pending a resolution on the legality of the strike.
ISSUE
Whether the Court of Industrial Relations, in a minimum wage dispute certified to it by the Secretary of Labor, retains the power to issue a return-to-work order pending final adjudication.
RULING
The Supreme Court ruled in the affirmative, upholding the CIR’s authority to issue the return-to-work order. The legal logic proceeds from a historical and integrated interpretation of the relevant statutes. While the Industrial Peace Act ( Republic Act No. 875 ) generally promotes collective bargaining and restricts courts from setting employment terms, it explicitly preserves exceptions under the Minimum Wage Law ( R.A. No. 602 ). The certification by the Secretary of Labor under this specific law effectively brings the dispute within the CIR’s compulsory arbitration powers. The Court reasoned that the CIR’s jurisdiction, once properly invoked under this exception, carries with it the ancillary authority to issue necessary provisional remedies, such as a return-to-work order, to maintain the status quo and prevent the exacerbation of the dispute. This power is essential to the effective exercise of its arbitral function and is consistent with the state’s police power to address labor disputes affecting national interest. The petitioners’ argument that the CIR must first rule on the strike’s legality before issuing such an order was found unpersuasive, as the provisional order is precisely aimed at restoring normalcy while the main case, including the strike’s legality, is being deliberated. Consequently, the CIR did not act without jurisdiction or with grave abuse of discretion. The petition for certiorari and prohibition was dismissed.