Benguet Consolidated, Inc. v. Coto Labor Union
REITERATIONFacts
The Antecedents: A dispute arose in 1956 between petitioner Benguet Consolidated, Inc. and respondent Coto Labor Union (NLU) concerning demands made by the union. The Secretary of Labor certified the dispute to the Court of Industrial Relations (CIR), docketed as Case No. 1029-V, and assigned to Presiding Judge Jose S. Bautista. Procedural History: Petitioner moved to dismiss for lack of jurisdiction, arguing the case should be heard en banc as it was certified under Section 16(c) of the Minimum Wage Law. The motion was denied, and an appeal to the CIR en banc was also denied. This Court, in G.R. No. L-12394, affirmed that such cases should be acted upon en banc but found the claim of petitioner inconsequential as Judge Bautista's decision was affirmed by the CIR en banc. The Petition: Upon remand, the trial judge set the case for hearing. Petitioner moved for postponement, citing the lack of formal complaint and answer and the need to join issues. Petitioner also filed a supplemental motion, reiterating that the case could only be heard en banc per this Court's ruling in G.R. No. L-12394. Respondent judge denied both motions, proceeding with the trial while stating he would receive evidence as a trial court or representative of the en banc. Petitioner filed the present petition, questioning whether the case could be heard by a single judge or only en banc.
Issue(s)
Whether the case certified to the Court of Industrial Relations concerning a minimum wage dispute should be heard by a single judge or by the court en banc. Whether a formal complaint and answer are necessary before proceeding with the trial.
Ruling
The petition is denied, and the order appealed from is affirmed. The preliminary injunction issued by this Court is dissolved.
Ratio Decidendi
On whether the case should be heard by a single judge or en banc: The Court reiterated its previous holding that cases of this nature, certified to the CIR concerning minimum wage, shall be decided en banc as provided by Section 16(c) of Republic Act 602. However, the Court clarified that this does not necessitate all judges sitting for the reception of evidence. It is sufficient that one judge be assigned to receive the evidence, who will then submit a report to the court en banc for deliberation and decision. A literal interpretation requiring all judges to sit during trial would be cumbersome, inexpeditious, and would jeopardize the functions of other judges. This interpretation is not the intendment of the law. On whether a formal complaint and answer are necessary: The Court held that such pleadings are unnecessary when the Secretary of Labor certifies a case to the industrial court. The certification itself specifies the points to be passed upon by the court. The crucial aspect is to set the case for hearing immediately to ensure its decision within the period prescribed by law.
Main Doctrine
While cases certified to the Court of Industrial Relations concerning minimum wage disputes should be decided en banc, the reception of evidence need not be by the entire court; one judge may receive evidence and submit a report to the en banc for deliberation and decision.