G.R. No. L-24489 September 28, 1968
AUGUSTIN GRACILLA, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, FULLER PAINT MANUFACTURING CO., (PHIL.), INC. and REPUBLIC PROTECTIVE AGENCY, respondents.

FACTS

Petitioner Augustin Gracilla filed a complaint with the Court of Industrial Relations (CIR) on March 12, 1963, objecting to his dismissal as a security guard by respondent Fuller Paint Manufacturing Co. (Phil.), Inc. He sought reinstatement and payment of various monetary claims, including unpaid services for Sundays and legal holidays, additional compensation for night services, salary differentials, earned vacation and sick leave pay, and back wages from the date of his alleged illegal dismissal. He sought to hold both Fuller Paint and the Republic Protective Agency (his direct employer before his services were availed of by Fuller Paint) jointly and severally liable for the money claims. The Presiding Judge of the CIR dismissed his complaint for lack of merit in a decision dated October 5, 1964, which, for humanitarian reasons, suggested that the Republic Protective Agency give Gracilla preferential assignment elsewhere or extend a separation fee. This decision did not address or rule upon Gracilla’s monetary claims. Gracilla filed a motion for reconsideration specifically pointing out that his claims for Sunday/holiday pay, night differential, and salary differential were overlooked. The CIR en banc denied the motion, failing to find justification to alter the decision, although Judge Amando C. Bugayong filed a concurring and dissenting opinion noting that the unresolved monetary claims were issues in the complaint that required resolution.

ISSUE

Whether the failure of the Court of Industrial Relations to rule upon the monetary claims raised by the petitioner in his complaint constitutes a denial of procedural due process.

RULING

Yes. The Supreme Court set aside the appealed CIR decision and resolution and remanded the case. The Court held that the CIR’s failure to pass upon the monetary claims timely raised and insisted upon by Gracilla at all stages of the proceeding amounted to a disregard of a cardinal primary right embedded in due process, as established in Ang Tibay v. Court of Industrial Relations. One of these essential requirements is that the court should render its decision such that the parties can know the various issues involved and the reasons for the decision, which duty is inseparable from its authority. By ignoring the issues of unpaid Sunday/holiday services, additional night compensation, and salary differentials, the CIR deprived Gracilla of this right. The analogy was drawn to Serrano v. Public Service Commission, where a similar failure by an administrative agency to decide on the merits and state reasons obstructed judicial review. The case was remanded to the CIR for a new consideration that must inquire into and pass upon the petitioner’s monetary claims.