G.R. No. L-17804; January 31, 1963
NATIONAL MARKETING CORPORATION and PRICE STABILIZATION CORPORATION (BOARD OF LIQUIDATORS), petitioners, vs. COURT OF INDUSTRIAL RELATIONS and PRISCO WORKERS UNION, ET AL., respondents.

FACTS

The case originated from a 1953 petition filed by 58 workers of the Price Stabilization Corporation (PRISCO) with the Court of Industrial Relations (CIR) for unpaid overtime and holiday pay. On August 25, 1953, the CIR rendered a partial decision ordering PRISCO to pay 25% additional compensation for such work rendered since June 8, 1951. This decision was later extended to other similarly situated PRISCO workers. Subsequently, PRISCO was abolished by Republic Act No. 1345 , transferring its assets and liabilities to the National Marketing Corporation (NAMARCO) and the Board of Liquidators. On March 20, 1958, 202 additional workers, including 45 employees of the General Auditing Office (GAO) assigned to PRISCO, filed a petition for payment based on the 1953 partial decision, covering work from June 8, 1951, to June 30, 1953.
Petitioners NAMARCO and the Board of Liquidators opposed the claim, arguing it had prescribed under the three-year period in the Eight-Hour Labor Law, as the 202 workers were not original parties. They also contended the 45 GAO employees were government auditors, not PRISCO employees, and thus not entitled to the corporate award. The CIR granted the workers’ petition in 1960, ordering payment after computation.

ISSUE

The issues are: (1) whether the claim of the 202 workers had prescribed; and (2) whether the 45 GAO employees assigned to PRISCO should be considered employees of the corporation for purposes of overtime and holiday compensation.

RULING

The Supreme Court partially granted the petition. On the first issue, the Court ruled the claim had not prescribed. The 1958 petition was not a new action but a motion for execution of the CIR’s final and executory partial decision of August 25, 1953. Under Section 23 of Commonwealth Act No. 103 , as amended, and Rule 39, Section 6 of the Rules of Court, a final judgment may be enforced by motion within five years from its entry. The filing in 1958 was within this five-year period, making the defense of prescription under the three-year period of the labor law inapplicable. The CIR properly extended the benefits to all similarly situated workers, as established in prior related cases.
On the second issue, the Court ruled the 45 GAO employees were not PRISCO employees entitled to the award. These auditors were appointed by and under the supervision of the Auditor General, with independent tenure and functions aimed at ensuring fiscal control and impartiality over the corporation. Their inclusion in PRISCO’s budget was merely a designation of the funding source, not an indication of an employer-employee relationship with the corporation. To maintain the independence essential to their auditing duties, they must be free from potential influence or benefits from the management they supervise. Consequently, they are governed by civil service laws and regulations applicable to regular government employees, not by the CIR’s award for corporate workers. The judgment was modified to exclude the GAO employees from the award.