Isaac Peral Bowling Alleys v. United Employees Welfare Association
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the reinstatement and back wages for four pinboys: Petronio Veriña, Claro Bordones, Carlos Menodiado, and Ramon Arevalo, employed by Isaac Peral Bowling Alleys. A prior decision by the Supreme Court affirmed an order from the Court of Industrial Relations (CIR) directing their reinstatement with back wages. 2. Procedural History: Following the Supreme Court's decision and a subsequent clarification allowing deductions for wages earned during suspension, the CIR proceeded to determine the exact amount of back wages due. This involved receiving evidence on the earnings of the four pinboys. The CIR issued an order on May 25, 1959, calculating the net back wages after deducting amounts earned by Petronio Beriña (P40.00) and Claro Bordones (P187.00) during their suspension. A motion for reconsideration by the Bowling Alleys was denied by the CIR en banc. 3. The Petition: The Isaac Peral Bowling Alleys filed a petition for certiorari with the Supreme Court, challenging the CIR's order and resolution. The petition was given due course only concerning Petronio Beriña and Claro Bordones. The Bowling Alleys argued that the CIR lacked jurisdiction to further hear the case for determining backpay, citing decisions related to Republic Act No. 875. They also contended that additional earnings of Beriña and Bordones should have been deducted. The Supreme Court found these arguments without merit, distinguishing the applicable law (Commonwealth Act No. 103) and noting that factual issues cannot be raised in a certiorari appeal.
Issue(s)
Whether the Court of Industrial Relations had jurisdiction to hear the case for the purpose of determining back pay after the effectivity of Republic Act No. 875. Whether additional earnings of Petronio Beriña and Claro Bordones, not included in the CIR's order, should have been deducted from their back wages.
Ruling
The Supreme Court affirmed the order and resolution of the Court of Industrial Relations. The Bowling Alleys were ordered to deposit P6,756.14 with the CIR.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations: The Court held that the CIR retained jurisdiction over the case. The case was commenced under Commonwealth Act No. 103, prior to the enactment of Republic Act No. 875. Pursuant to Section 27 of Republic Act No. 875, the CIR's jurisdiction over cases commenced before its approval is retained until all issues are fully settled and disposed of. Therefore, the CIR could continue hearing incidents of the case, applying the provisions of Commonwealth Act No. 103. On the deduction of additional earnings: The Court ruled that questions of fact cannot be raised in an appeal by certiorari under Commonwealth Act No. 103. The petitioner's claim that additional sums were earned by Petronio Beriña and Claro Bordones constituted a question of fact. Since the case was before the Supreme Court on appeal by certiorari under Commonwealth Act No. 103, such factual issues could not be considered. The Court cited several previous decisions to support the principle that factual matters are not reviewable in this mode of appeal.
Main Doctrine
The Court of Industrial Relations retains jurisdiction over cases commenced prior to the effectivity of Republic Act No. 875 to hear and decide all incidents thereof until fully settled, applying Commonwealth Act No. 103. Questions of fact cannot be raised in an appeal by certiorari under Commonwealth Act No. 103.