GR L 9448; (May, 1957) (Digest)
G.R. No. L-9448; May 23, 1957
Baselides Marcelo, Juanito Bolano, Exequiel Naje, Felix San Mateo, Pascual Andrade, Marciano Ferrolino, Isidro Bongay, Antolin Balubar, Irineo Marquez, Jose T. Rico, Ulpiano Gutlay and Esteban Madera, plaintiffs-appellants, vs. Philippine National Red Cross and its Board of Governors, defendants-appellees.
FACTS
The plaintiffs, employees of the Philippine National Red Cross (PNRC) in various capacities such as janitors, drivers, technicians, and manual laborers, filed an action in the Court of First Instance of Manila. They alleged that since March 22, 1947, they had rendered substantial overtime services, including on Sundays and holidays, for which each was owed approximately P5,000. The complaint also included a claim for underpayment under the Minimum Wage Law for plaintiff Esteban Madera. The defendants filed a motion for a bill of particulars, which the court granted, directing the plaintiffs to specify details such as the exact overtime hours, rates of pay, and dates. After the plaintiffs submitted their bill of particulars, the defendants moved to dismiss the complaint on the ground that it failed to state a valid cause of action. The lower court dismissed the complaint, holding that the Eight-Hour Labor Law (Commonwealth Act No. 444) did not apply to the PNRC because the law applies only to persons employed in an “industry or occupation,” and the PNRC, as a charitable institution devoted to humanitarian work and not engaged in profit-making, does not fall under this category. The court reasoned that applying the law to the PNRC would divert its limited funds from relief work to overtime pay, contrary to legislative intent. The plaintiffs appealed.
ISSUE
The sole issue on appeal is whether the provisions of the Eight-Hour Labor Law (Commonwealth Act No. 444) apply to the employees of the Philippine National Red Cross, a charitable institution.
RULING
The Supreme Court affirmed the order of the lower court dismissing the complaint. The Court held that the Eight-Hour Labor Law, by its express terms in Section 2, applies only to “persons employed in an industry or occupation.” The Court determined that the Philippine National Red Cross is not engaged in an “industry or occupation” as contemplated by the law. The PNRC is a charitable institution devoted purely to humanitarian work, funded by voluntary contributions and not engaged in profit-making. Therefore, its employees cannot demand the benefits of the Eight-Hour Labor Law as a matter of right. The Court noted that the PNRC’s Board of Governors could, as a matter of policy and if finances permit, extend such benefits to its employees, but this is discretionary and not a legal obligation. The Court also found that the lower court’s order did not address the Minimum Wage Law (Republic Act No. 602), making the plaintiffs’ second assignment of error without basis.
