GR 117078; (February, 1995) (Digest)
March 11, 2026GR 113591; (February, 1995) (Digest)
March 11, 2026G.R. No. L-4634 April 28, 1952
SAN MIGUEL BREWERY, INC., petitioner, vs. THE HON. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.
FACTS
In CIR Case No. 271-V, San Miguel Brewery, Inc. (SMB) filed a petition against the National Labor Union (NLU) and San Miguel Brewery Employees and Laborers Association (SAMBELA). The decision of September 17, 1949, based on a stipulation of the parties, ordered that there be no dismissal, suspension, or transfer except for just cause. On April 15, 1950, SMB dismissed laborer Santos Ortiz allegedly for cause. Subsequently, the NLU and SAMBELA filed a motion in July 1950 in the same Case No. 271-V, praying for the reinstatement of Ortiz on the ground that his dismissal was without just cause and violated the 1949 decision, and for contempt proceedings. SMB questioned the authority of Atty. Eulogio R. Lerum to file for SAMBELA, alleging SAMBELA had disauthorized him and was dissolved. Atty. Lerum then filed an amended motion solely on behalf of the NLU, reiterating the same allegations. This amended motion was docketed as a separate Case No. 478-V and assigned to the Second Branch of the CIR. SMB filed a motion to dismiss, contending the CIR lacked jurisdiction because the dispute involved only one laborer and thus did not meet the requirement of involving more than 30 laborers under Section 4 of Commonwealth Act No. 103. The CIR denied the motion to dismiss, holding that the amended motion was so closely connected with Case No. 271-V that the court’s jurisdiction, which had already attached in that case, extended to it. SMB’s motion for reconsideration was denied, prompting this petition for certiorari.
ISSUE
Whether the Court of Industrial Relations has jurisdiction to entertain the amended motion (docketed as Case No. 478-V) concerning the dismissal of a single laborer, Santos Ortiz.
RULING
Yes, the Court of Industrial Relations has jurisdiction. The Supreme Court affirmed the CIR’s order denying the motion to dismiss. The amended motion filed by the NLU, although docketed separately, was in essence a part of and an incident to CIR Case No. 271-V. The right sought to be enforced (reinstatement based on the “no dismissal except for just cause” stipulation) springs directly from the 1949 decision in that case. The CIR has the power under Section 17 of Commonwealth Act No. 103 to reopen any question involved in a decision at any time during its effectiveness. Furthermore, the CIR possesses inherent powers to compel obedience to its judgments and to enforce its decisions under Section 23 of the same Act. Treating the dismissal as a separate case for an ordinary court would frustrate the purposes of the law creating the CIR. The dissolution of SAMBELA did not affect the CIR’s jurisdiction, as the NLU and Ortiz himself were interested parties. The assignment of the amended motion to the Second Branch was valid, as a court composed of several branches is deemed a single totality, and one branch may act on matters related to a case originally heard by another.
