GR L 7175; (April, 1956) (Digest)
G.R. No. L-7175; April 27, 1956
GOVERNMENT SERVICE INSURANCE SYSTEM, petitioner, vs. HON. MODESTO CASTILLO, ET AL., respondents.
FACTS
The Government Service Insurance System (GSIS) filed a petition for a writ of prohibition with preliminary injunction to enjoin Judge Modesto Castillo of the Court of Industrial Relations (CIR) from hearing CIR Case No. 895-V, alleging lack of jurisdiction. The case originated from a labor dispute where the respondent association of GSIS employees submitted fourteen demands, including salary scales, family allowances, and overtime pay. After conciliation efforts by the Secretary of Labor partially resolved some issues, the employees declared a strike on June 17, 1953. The Secretary then certified the dispute to the CIR. GSIS moved to dismiss the case, arguing that its employees are civil service employees governed by the Civil Service Law, thus placing the dispute outside the CIR’s jurisdiction. The CIR denied the motion to dismiss.
ISSUE
Whether the Court of Industrial Relations has jurisdiction over the labor dispute involving employees of the Government Service Insurance System, a government-owned or controlled corporation.
RULING
The Supreme Court dismissed the petition, upholding the jurisdiction of the Court of Industrial Relations. The Court ruled that GSIS, created as a non-stock corporation under Commonwealth Act No. 186, as amended, is engaged in a proprietary function—the business of insurance—which is not inherently or exclusively a governmental function. Citing precedents such as National Airports Corporation vs. Teodoro and Manila Hotel Employees Association vs. Manila Hotel Company, the Court emphasized that government-owned or controlled corporations engaged in proprietary functions fall under the jurisdiction of the CIR for labor disputes. The Court further noted that Commonwealth Act No. 103 (creating the CIR) does not exclude civil service employees from its jurisdiction, and Republic Act No. 875 (the Industrial Peace Act) implicitly supports this by distinguishing between governmental and proprietary functions of the government. Therefore, the CIR properly assumed jurisdiction over the case, including the strike declared by the employees.