G.R. No. L-17871, L-18200, L-18160, L-18249. January 31, 1964
MANILA RAILROAD COMPANY, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and STATION EMPLOYEES’ UNION, et al., respondents.

FACTS

The Manila Railroad Company (MRR), a government-owned corporation, was the subject of consolidated petitions filed by three separate labor unions representing its station employees, yard crew, and train operators/firemen. The unions alleged that MRR failed to pay additional compensation for work rendered in excess of eight hours a day and forty hours a week, as mandated by Commonwealth Act No. 444 (The Eight-Hour Labor Law) and Republic Act No. 1880 (The Forty-Hour Week Law). They sought a directive for MRR to comply with these laws and to pay corresponding wage deficiencies. MRR moved to dismiss the petitions, arguing that the Court of Industrial Relations (CIR) lacked jurisdiction and that, as a public utility, it was exempt from the coverage of these laws, especially concerning work on the sixth and seventh days of the week.
The CIR, in separate but identical rulings, asserted jurisdiction and held that MRR was not exempt from RA 1880. It ordered MRR to implement the law and to pay double compensation for work rendered on the sixth and seventh days of the week, based on its prior decision in a related case. MRR’s motions for reconsideration were denied by the CIR en banc, prompting these petitions for certiorari.

ISSUE

The primary issue is whether the Manila Railroad Company, as a government-owned public utility corporation, is obligated to pay its employees additional compensation for work exceeding eight hours a day and forty hours a week under CA 444 and RA 1880, and specifically, whether it must pay double compensation for work on the sixth and seventh days.

RULING

The Supreme Court affirmed the CIR’s jurisdiction and its finding that MRR is bound by RA 1880. The Court clarified that RA 1880 applies to all government-owned or controlled corporations, and MRR does not fall under the statutory exceptions (e.g., schools, hospitals). Therefore, MRR must comply with the forty-hour workweek and pay additional compensation for overtime.
However, the Court modified the CIR’s order regarding compensation for work on the sixth and seventh days (Sundays and legal holidays). Citing Section 4 of CA 444, the Court held that as a public utility providing transportation, MRR may compel its employees to work on Sundays and legal holidays. For such work not exceeding eight hours, employees are entitled only to their regular daily wage. If the work exceeds eight hours, they are entitled to their regular wage plus at least a twenty-five percent additional compensation for the overtime hours. The CIR’s award of double compensation for work on these days was found to have no legal basis and was thus set aside. The claims were deemed not prescribed, having been filed within the period allowed by RA 1993. The rest of the CIR’s judgments were affirmed.