U.S.T. Hospital Employees Association v. Sto. Tomas University Hospital
REITERATIONFacts
The Antecedents: The U.S.T. Hospital Employees Association filed a case before the Court of Industrial Relations (CIR) against the Sto. Tomas University Hospital concerning disputes related to their employment. The parties submitted a stipulation of facts on February 3, 1953. Procedural History: The CIR, through Judge Bautista, dismissed the case on July 7, 1953, ruling that the court lacked jurisdiction. A motion for reconsideration was denied by the majority of the CIR judges (Roldan, Bautista, and Jimenez Yanson), with Judges Lanting and Castillo dissenting. The Petition: The U.S.T. Hospital Employees Association filed a petition for certiorari with the Supreme Court, contending that the CIR erred in declaring itself without jurisdiction to hear the case.
Issue(s)
Whether the Court of Industrial Relations has jurisdiction over disputes arising from the employment of individuals in a hospital operated by a university, which is not primarily established for profit. Whether the employment in the St. Tomas University Hospital constitutes 'industrial employment' as contemplated by law.
Ruling
The petition is denied. The Supreme Court affirmed the order of dismissal issued by the Court of Industrial Relations, holding that the CIR did not err in declaring itself without jurisdiction.
Ratio Decidendi
On Issue 1: The Court held that the Court of Industrial Relations (CIR) is a special court with limited jurisdiction, defined by the law that created it. Its jurisdiction is confined to 'industrial disputes' arising between employers and employees or laborers, and landlords and tenants or farm-laborers. The Court examined the nature of the Sto. Tomas University Hospital, as established by the stipulation of facts and evidence presented. It found that the hospital, while having pay wards, also has charity wards, and its income from pay wards is used to finance the expenses of the free wards. The University of Sto. Tomas itself even subsidizes the medicines for patients in the free ward. This operational model clearly indicates that the hospital is a charitable institution, not established primarily for profit. Therefore, disputes arising from employment in such an institution do not qualify as 'industrial disputes' within the meaning of Commonwealth Act No. 559 and Republic Act No. 772, thus falling outside the CIR's jurisdiction. On Issue 2: The Court clarified that for a dispute to be considered an 'industrial dispute' under the jurisdiction of the CIR, the employment must be 'industrial employment.' Republic Act No. 772 defines 'industrial employment' in the context of private employers as all employment or work at a trade, occupation, or profession exercised by an employer for the purpose of gain, excluding domestic service. Since the Sto. Tomas University Hospital was found to be a charitable institution operating not for profit, the positions occupied by the members of the petitioner association do not constitute 'industrial employment.' Consequently, the controversy between the hospital and its employees is not an 'industrial dispute,' and the CIR correctly ruled that it lacked jurisdiction over the matter.
Main Doctrine
The Court of Industrial Relations' jurisdiction is limited to 'industrial disputes' as defined by law, which pertains to employment in enterprises established for the purpose of gain. Employment in a charitable institution, such as the St. Tomas University Hospital, which operates not for profit but for the service of humanity and the instruction of medical students, does not fall under the definition of 'industrial employment.' Consequently, controversies arising from such employment are outside the jurisdiction of the Court of Industrial Relations.