G.R. No. L-17661 December 28, 1961
MANUEL TIBERIO, petitioner, vs. MANILA PILOTS ASSOCIATION, respondent.

FACTS

Petitioner Manuel Tiberio filed a complaint in the Court of Industrial Relations (CIR) against respondent Manila Pilots Association to recover overtime compensation for services rendered as a sailor from June 7, 1953, to June 30, 1955. He alleged he went on vacation due to illness at the end of this period. The respondent moved to dismiss the complaint on two grounds: first, that the CIR lacked jurisdiction over the subject matter, and second, that the action had already prescribed under the applicable statute of limitations.
The CIR issued an order declaring itself without jurisdiction over the claim. This order was affirmed by the court en banc, prompting Tiberio to elevate the matter to the Supreme Court via a petition for review. The central dispute revolved around whether the CIR correctly dismissed the case based on these jurisdictional and prescription arguments without proceeding to a trial on the merits.

ISSUE

The primary issues were: (1) whether the Court of Industrial Relations had jurisdiction over Tiberio’s claim for overtime compensation, and (2) whether his cause of action had prescribed.

RULING

The Supreme Court reversed the CIR’s order and remanded the case for further proceedings. On jurisdiction, the Court held the CIR erred in dismissing the complaint. The ruling emphasized that Tiberio’s complaint contained an allegation that he was employed until June 30, 1955, “when claimant went on vacation because of illness.” This indicated a subsisting employer-employee relationship at the time the complaint was filed, as the phrasing suggested he was on leave, not terminated. Following the settled doctrine established in cases like Sampaguita Pictures, Inc. v. Court of Industrial Relations, the CIR possesses exclusive jurisdiction over money claims for overtime pay when an employer-employee relationship exists, even if no prayer for reinstatement is included. The respondent’s denial of this factual allegation did not negate it for purposes of a motion to dismiss; it merely created an evidentiary issue to be resolved during a full trial.
Regarding prescription, the Court also found the CIR’s ruling erroneous. The CIR held the action prescribed because it was filed more than three years after the cause of action accrued in 1955. However, the Supreme Court noted that Tiberio had previously filed claims for the same overtime compensation with the Department of Labor on August 8, 1957, and March 18, 1958. The filing of these claims with the proper administrative body effectively interrupted the running of the prescriptive period under Republic Act No. 1993 . Finally, the Court rejected any argument that jurisdiction was transferred to a regional office under Reorganization Plan No. 20-A, reiterating in line with Corominas, Jr. v. Labor Standards Commission that the Reorganization Commission could not validly divest courts of their judicial jurisdiction.