G.R. No. L-16440; February 29, 1964
PHILIPPINES ENGINEERS’ SYNDICATE, INC., petitioner, vs. HON. JOSE S. BAUTISTA, ARSENIO I. MARTINEZ, BALTAZAR M. VILLANUEVA, EMILIO C. TABIGNE and AMADO C. BUGAYONG, Presiding Judge and Associate Judges respectively of the Court of Industrial Relations; FEDERICO BENITEZ, DEWEY BAYING, ANDRES ULAS, DELFIN GALASGAS, QUEZON BASORA, ET AL., respondents.

FACTS

The petitioner, Philippines Engineers’ Syndicate, Inc., is a domestic construction corporation. On December 28, 1958, respondent Federico Benitez and 64 other employees filed a complaint with the Court of Industrial Relations (CIR). They alleged that while employed by the petitioner in various capacities, they had rendered nighttime service during specific periods. They claimed that for this night work, they were paid only the regular daytime wage without the additional 50% compensation they believed they were entitled to receive. The complaint included a detailed schedule of the workers’ names, rates, days worked, and the claimed differential.
The petitioner moved to dismiss the complaint, primarily on the ground that the CIR lacked jurisdiction over the subject matter following the enactment of Republic Act No. 875 (the Industrial Peace Act). It argued that the CIR’s jurisdiction was now limited to specific cases, such as those involving industries indispensable to the national interest, minimum wage, hours of employment under the Eight-Hour Labor Law, and unfair labor practices. The petitioner contended that a claim for additional compensation for regular night work did not fall into any of these categories. The Presiding Judge of the CIR ruled that the court was competent to take cognizance of the case, a ruling later affirmed by the CIR en banc.

ISSUE

Whether the Court of Industrial Relations retained jurisdiction over claims for additional compensation for regular night work after the passage of Republic Act No. 875 .

RULING

The Supreme Court ruled affirmatively, holding that the CIR retained jurisdiction over such claims. The Court rejected the petitioner’s argument that Republic Act No. 875 had stripped the CIR of jurisdiction over all matters except the four enumerated categories. The legal logic proceeds from a distinction between the general grant of jurisdiction under Commonwealth Act No. 103 and the specific limitations introduced by the later law. While Republic Act No. 875 did curtail the CIR’s broad powers to encourage collective bargaining, it did not completely divest the court of its authority over wage-related disputes like the one at bar.
Crucially, the Court cited its precedent in Shell Co. vs. National Labor Union, which established that the CIR, under its general powers to fix just and reasonable wages, inherently possesses the authority to determine proper compensation for night work, recognizing it as more onerous than daytime labor for hygienic, medical, and sociological reasons. The Court further noted its post- Republic Act No. 875 decisions consistently upholding the CIR’s jurisdiction over cases for salary differentials, overtime pay, and additional compensation for night, Sunday, and holiday work. To rule otherwise would constitute an undue further curtailment of the CIR’s jurisdiction, contrary to the protective spirit of labor legislation. Therefore, the CIR correctly assumed jurisdiction over the employees’ claim for night differential pay. The challenged orders were affirmed, and the petition was dismissed.