G.R. No. L-18091; June 29, 1963
PHILIPPINE MANUFACTURING COMPANY, petitioner, vs. ANG BISIG NG PMC, ALBERTO TEODORO, ALEJANDRO JOAQUIN and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The Philippine Manufacturing Company (PMC) and its employees’ union, Ang Bisig ng PMC, had a long-standing agreement from 1947 to 1953 establishing a three-shift schedule in the production department: 7 a.m. to 3 p.m., 3 p.m. to 11 p.m., and 11 p.m. to 7 a.m. The union later filed a petition with the Court of Industrial Relations (CIR) seeking to compel PMC to pay 50% extra compensation for work performed between 12:01 a.m. and 7 a.m. on Sundays and legal holidays during that period. PMC contested the claim, arguing that under the agreed schedule, a workday ran from 7 a.m. of one day to 7 a.m. of the next, making the early Sunday hours part of the Saturday workday and thus not entitled to extra pay.
The CIR’s Presiding Judge ruled in favor of the union, ordering PMC to pay the 50% additional compensation. PMC filed a motion for reconsideration, requesting an oral argument before the CIR en banc. The CIR en banc denied the motion without holding an oral argument. PMC appealed to the Supreme Court, raising procedural and substantive errors.

ISSUE

1. Did the CIR en banc deny PMC due process by resolving its motion for reconsideration without an oral argument?
2. Was the CIR correct in ordering extra compensation for work done between 12:01 a.m. and 7 a.m. on Sundays and legal holidays, despite the parties’ shift agreement?

RULING

The Supreme Court affirmed the CIR’s decision. On the procedural issue, the Court held that a hearing for oral argument on a motion for reconsideration is discretionary with the CIR. Its refusal to grant one did not constitute a denial of due process absent a showing of abuse of discretion, which was not present. The Court also found that the CIR judges complied with the legal requirement to “sit together” in resolving the motion, as their collective signatures on the resolution indicated prior consultation and deliberation.
On the substantive issue, the Court ruled that the CIR did not invalidate the parties’ shift agreement. The validity of the agreed third shift (11 p.m. to 7 a.m.) was not in question. The core issue was whether work performed on a Sunday or legal holiday as a result of that schedule warranted extra compensation. The Court held that it did, as the matter is governed by mandatory law. Commonwealth Act No. 444 (the Eight-Hour Labor Law) requires payment of an additional sum of at least 25% for work on Sundays and legal holidays and declares any contrary agreement null and void. The CIR merely enforced this law. Since the collective bargaining agreement between PMC and the union provided for a 50% differential for Sunday work—a practice more beneficial to employees than the statutory minimum—the CIR correctly ordered payment at this agreed higher rate. PMC’s estoppel argument failed because the law’s provisions on extra pay for holiday work are mandatory and cannot be waived by agreement.