GR L 11135; (April, 1958) (Digest)
G.R. No. L-11135; April 30, 1958
H. E. HEACOCK CO., petitioner, vs. NATIONAL LABOR UNION, The HONORABLE JOSE S. BAUTISTA, JUAN L. LANTING and ARSENIO T. MARTINEZ, all Judges of the Court of Industrial Relations, respondents.
FACTS
The National Labor Union (respondent) filed a motion in the Court of Industrial Relations (CIR) in Case No. 458-V, seeking an order for H. E. Heacock Co. (petitioner) to pay bonuses equivalent to three months’ salary to employees who had not received them for the years 1950, 1951, and 1952. The motion alleged that in 1948, the company granted a bonus for 1947 profits and promised yearly bonuses if profits continued; that profits were made in 1950-1952; but bonuses were paid only to high-salaried officials, discriminating against low-salaried employees. This motion was filed on May 9, 1953. Previously, in a related case (also No. 458-V), the CIR had ordered the company to pay bonuses for 1948 and 1949, a decision which was appealed to the Supreme Court and decided on July 31, 1954. The CIR granted the motion for 1950-1952 bonuses in an order dated July 12, 1956. H. E. Heacock Co. challenged this order via certiorari, arguing the CIR lacked jurisdiction.
ISSUE
Whether the Court of Industrial Relations had jurisdiction over the motion seeking payment of bonuses for the years 1950, 1951, and 1952.
RULING
The Supreme Court granted the petition for certiorari, reversed the CIR order, and dismissed the motion. The Court held that the CIR lacked jurisdiction. The motion sought to enforce distinct money claims for bonuses for 1950-1952, separate from the earlier case covering 1948-1949. The right to these bonuses depended on new factual issues, such as whether profits were actually made in those specific years. Crucially, the motion contained no allegation that the dispute was causing or likely to cause a strike or lockout. Under Commonwealth Act No. 103 , the CIR’s jurisdiction was limited to industrial disputes “causing or likely to cause a strike or lockout.” Since the motion merely asserted a money claim based on an alleged past promise without showing such imminent labor trouble, it fell outside the CIR’s jurisdictional authority. The cited precedents (San Miguel Brewery and Manila Trading) were deemed inapplicable as they involved enforcement of orders integral to the main pending dispute, not new and separate claims.