G.R. No. L-14258; July 26, 1960
NATIONAL DEVELOPMENT COMPANY, petitioner, vs. JUAN ARALAR, ET AL. and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The National Development Company (NDC) filed a petition for certiorari to appeal the decision of the Court of Industrial Relations (CIR) dated June 28, 1958. The CIR decision granted the petition of Juan Aralar and 69 others, filed on April 22, 1957, seeking the execution of a prior CIR decision dated November 5, 1948 (Case No. 129-V). The 1948 decision ordered NDC to grant a minimum wage increase and a 10% salary increase to employees earning not more than P300.00 monthly and laborers receiving P5.00 a day or more, effective March 15, 1948. NDC moved to dismiss the 1957 petition on grounds that it was a money claim not cognizable by the CIR under Republic Act No. 875, that it stated no cause of action, that the CIR lacked jurisdiction as the petition was not signed by at least 31 claimants as required by Commonwealth Act 103, and that a notice to terminate the 1948 award had been filed. The CIR denied the motion to dismiss, treated the petition as one for execution of its prior decision, and after hearing, granted it. The CIR directed its examiner to compute the 10% increase due, including for petitioners who had died, were laid off, or were dismissed after March 15, 1948. NDC’s motion for reconsideration was denied by the CIR en banc.

ISSUE

1. Whether the CIR had jurisdiction over the petition filed by Juan Aralar et al. for the execution of its 1948 decision.
2. Whether a mere notice to terminate an award is sufficient to stop its effectivity.
3. Whether the CIR had jurisdiction over the claims of petitioners who were no longer in the service of NDC.

RULING

The Supreme Court affirmed the CIR decision, with conditions, and remanded the case for further proceedings.
1. On Jurisdiction over the Petition: The Court agreed with the CIR that the present petition was not an independent action but a mere request for execution of the 1948 award in Case No. 129-V. Consequently, the jurisdictional elements for initiating a new case (e.g., a labor dispute likely to cause a strike, signature by at least 31 claimants) were not required. The petition was properly treated as a continuation of the original case.
2. On Effect of Notice to Terminate: The Court held that a mere notice filed by the company to terminate the effectivity of the 1948 award was insufficient to bar its enforcement. Following the precedent in National Waterworks and Sewerage Authority (NAWASA) vs. Court of Industrial Relations, the law requires a hearing before the CIR to decide whether the award should continue based on prevailing conditions (e.g., changes in the company’s financial status). The notice merely gives the CIR the right to intervene.
3. On Jurisdiction over Ex-Employees: The Court distinguished between a mere money claim and a petition for enforcement of a CIR award. For jurisdictional purposes, a money claim (e.g., for overtime, underpayment) filed by ex-employees who do not seek reinstatement falls under the jurisdiction of regular courts, as the employer-employee relationship has ceased and there is no potential labor dispute. However, a petition for the execution of a final CIR award is not treated as a simple money claim. The Court affirmed the CIR’s jurisdiction to order execution for all beneficiaries of the 1948 award, including those no longer employed, as it was an enforcement proceeding of its own final order.
* Condition and Limitation: The Supreme Court imposed a condition on its affirmation. The confirmation of the CIR decision is made with the understanding that the 1948 award is still enforceable, meaning that not more than five years have elapsed since the last execution of the award and the date of the present petition (April 22, 1957). The benefits of the award may only be extended to laborers and employees of NDC’s textile mills and other departments who are similarly situated. The case was remanded to the CIR for determination of the amounts due in accordance with this ruling.