GR 35254; (May, 1973) (Digest)
G.R. No. L-35254. May 25, 1973.
THE PHILIPPINE AMERICAN MANAGEMENT COMPANY, INC., 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 arose between the petitioners (companies) and the respondent union concerning a minimum wage question, which resulted in a strike. The Secretary of Labor, after a failed conciliation, endorsed the dispute to the Court of Industrial Relations (CIR). The CIR, exercising its arbitral power, issued a return-to-work order pending the final resolution of the controversy. The petitioners challenged this order, arguing it violated the basic philosophy of the Industrial Peace Act (Republic Act No. 875), which promotes free collective bargaining and retreats from compulsory arbitration.
In a decision promulgated in January 1973, the Supreme Court upheld the CIR’s jurisdiction to issue the return-to-work order. The petitioners filed a motion for reconsideration, reiterating their core arguments. They contended that the CIR’s compulsory arbitration power, including issuing return-to-work orders, was fundamentally at war with the Industrial Peace Act’s regime of free bargaining. They also attempted to distinguish the act of the Secretary of Labor from an act of the President to undermine the authority behind the endorsement to the CIR.
ISSUE
Whether the Court of Industrial Relations had jurisdiction to issue a return-to-work order in a minimum wage dispute endorsed by the Secretary of Labor, notwithstanding the provisions of the Industrial Peace Act.
RULING
The Supreme Court denied the motion for reconsideration and affirmed its prior ruling. The Court explained that while the Industrial Peace Act generally enshrines industrial democracy and free collective bargaining, the question of minimum wages constitutes a non-negotiable area expressly placed beyond the sphere of bargaining between parties. Legislation on minimum wages establishes a compulsory floor to assure decent living, and what the law decrees must be obeyed. Therefore, petitioners could not successfully invoke principles of free bargaining to defeat the CIR’s jurisdiction over this specific matter.
The Court further held that the Industrial Peace Act explicitly continued the CIR’s jurisdiction over minimum wage controversies endorsed by the Secretary of Labor. This grant necessarily included the power of compulsory arbitration to make its jurisdiction effective, which encompassed the authority to issue return-to-work orders to prevent the exacerbation of the dispute. The act of the Secretary of Labor in endorsing the case is, under the settled doctrine in Villena v. The Secretary of the Interior, an act of the Executive President. Consequently, no valid objection could be interposed to the CIR exercising its full arbitral powers pursuant to such endorsement. The petitioners’ persistence in their arguments did not justify a departure from these established legal principles.