G.R. No. L-34300 November 22, 1974
LUZON STEVEDORING CORPORATION and B.H. TENEFRANCIA, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and GERARDO MIÑOZA, respondents.

FACTS

Private respondent Gerardo Miñoza was employed by petitioner Luzon Stevedoring Corporation since 1931, rising to the position of Stevedoring Supervisor in 1952 at its Davao City branch. On May 24, 1962, he received a letter from office manager Benjamin Tenefrancia stating that due to a reorganization, his services were being terminated effective June 1, 1962, with an offer of separation pay. Miñoza, through counsel, contested the dismissal as without just cause and demanded reinstatement with back wages. The corporation refused, and Miñoza was replaced by Rodolfo Liboon, who was given a higher monthly salary. Miñoza subsequently filed a complaint with the Court of Industrial Relations (CIR) for illegal dismissal, seeking reinstatement with back wages and overtime pay.
The petitioners contested the CIR’s jurisdiction, arguing that Miñoza, as a supervisor, was a managerial employee and thus his dismissal fell under the Termination Pay Law ( Republic Act No. 1052 ), which did not provide for reinstatement. They also claimed the dismissal was due to a legitimate reorganization and that Miñoza’s money claims had prescribed. The CIR ruled in favor of Miñoza, ordering his reinstatement with full back wages from June 1, 1962, to April 17, 1968, and overtime pay for a limited period.

ISSUE

The primary issues were: (1) whether the CIR had jurisdiction over the complaint; (2) whether Miñoza was illegally dismissed; and (3) the proper computation of back wages and overtime pay.

RULING

The Supreme Court affirmed the CIR’s decision with modifications. On jurisdiction, the Court held that the CIR validly acquired jurisdiction because the complaint alleged a violation of the Eight-Hour Labor Law alongside the claim for illegal dismissal. The allegations in the complaint determine jurisdiction, and the claim for overtime pay brought the case within the CIR’s authority.
On the merits, the Court upheld the CIR’s factual finding that Miñoza was illegally dismissed. The purported reorganization was not a valid cause for termination, as it was a mere pretext, evidenced by the immediate hiring of a replacement at a higher salary. The Court also rejected the claim that Miñoza was a managerial employee exempt from reinstatement remedies. The evidence showed his power to hire and fire subordinate stevedores was subject to the branch manager’s approval and was merely routinary, not involving independent judgment characteristic of managerial staff.
Regarding awards, the Court modified the back wages. Following the prevailing policy to expedite execution, back wages were limited to three years from the date of dismissal without deduction or proof of income earned elsewhere. The award for overtime pay was correctly limited by the CIR to three years preceding the filing of the complaint, pursuant to the prescriptive period under the Eight-Hour Labor Law. Thus, petitioners were ordered to reinstate Miñoza without loss of seniority, pay three years of back wages, and pay overtime compensation for three years as computed by the CIR.