G.R. No. L-19557; March 31, 1964
MANILA ELECTRIC COMPANY, petitioner, vs. PASCUAL ORTAÑEZ, FRANCISCO P. GENEROSO, COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.

FACTS

Petitioner Manila Electric Company (Meralco) sought to prohibit the Court of Industrial Relations (CIR) from taking cognizance of a case filed by its employees, Pascual Ortañez and others. The employees’ petition alleged that since 1956, they had rendered overtime and night work for which they were not paid the corresponding overtime wages and a 25% night premium pay. They claimed these benefits were granted to all other company employees pursuant to a collective bargaining agreement, and Meralco’s refusal to pay violated Commonwealth Act No. 444 (The Eight-Hour Labor Law). The petition did not specify a definite sum of money claimed.
Meralco moved to dismiss the case before the CIR on jurisdictional grounds, arguing that the number of employee-petitioners involved was only 20, which did not exceed the 30-employee minimum required by Commonwealth Act No. 103 for the CIR to acquire jurisdiction. A majority of the CIR denied the motion, holding it had authority to enforce labor laws. One judge dissented, agreeing with Meralco’s jurisdictional argument and also characterizing the claim as a simple money demand outside the CIR’s purview.

ISSUE

Whether the Court of Industrial Relations correctly assumed jurisdiction over the employees’ claim for unpaid overtime and night premium pay.

RULING

The Supreme Court denied Meralco’s petition for certiorari and prohibition, thereby allowing the CIR to proceed with hearing the case. The Court’s legal logic centered on the nature of the claim as pleaded and the principle of determining jurisdiction based on facts to be proven at trial, not merely on the complaint’s allegations.
The Court clarified that the employees’ petition was not a simple action for a sum of money, as it demanded no specific amount. Instead, it was in the nature of mandamus to compel payment of benefits allegedly withheld in violation of law and a collective bargaining agreement. The allegation that all other employees except the petitioners received these benefits raised potential issues of discrimination and unfair labor practice, matters traditionally within the CIR’s jurisdiction. Furthermore, the claim of a violation of the Eight-Hour Labor Law itself could bring the case under the CIR’s authority to enforce labor statutes.
The Supreme Court held that whether the CIR ultimately had jurisdiction would depend on the facts to be established during the trial—such as the precise nature of the collective bargaining agreement and whether the dispute involved its interpretation or enforcement in a manner constituting an unfair labor practice. Applying the procedural principle that doubts should be resolved against dismissal at the pleading stage, the Court ruled it was premature to prohibit the CIR from hearing the case. Jurisdiction should be ascertained after evidence is presented, not on the basis of the petition’s allegations alone.