Tiberio v. Manila Pilots Assn.
REITERATIONFacts
The Antecedents: Petitioner Manuel Tiberio filed a complaint against respondent Manila Pilots Association seeking to recover P5,204.37 as overtime compensation for services rendered as a sailor from June 7, 1953, to June 30, 1955, when he went on vacation due to illness. Procedural History: Respondent moved to dismiss the complaint, asserting lack of jurisdiction and prescription. The Court of Industrial Relations (CIR) issued an order declaring itself without jurisdiction, which was affirmed en banc. The Petition: Petitioner sought a review of the CIR's order of dismissal.
Issue(s)
Whether the Court of Industrial Relations has jurisdiction over the claim for overtime compensation. Whether the action has prescribed.
Ruling
The order of dismissal is set aside, and the case is remanded to the court a quo for further proceedings. No pronouncement as to costs.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the CIR erred in dismissing the complaint for lack of jurisdiction. While the claim was for overtime compensation and did not explicitly seek reinstatement, the allegation that the petitioner went on vacation due to illness indicated a subsisting employer-employee relationship at the time the complaint was filed. It is a settled doctrine that the CIR has jurisdiction over claims for unpaid wages or overtime pay if an employer-employee relationship exists, even without a prayer for reinstatement. The denial of this relationship by the respondent does not negate the averment but merely reduces it to evidentiary matter to be threshed out during trial on the merits. The Court cited the case of Sampaguita Pictures, Inc., et al. v. Court of Industrial Relations, et al. to support this ruling, emphasizing that the existence of the employer-employee relationship is crucial for the CIR's jurisdiction in such money claims. On the issue of prescription: The Court found the ruling on prescription to be devoid of merit. The petitioner had previously filed claims for the same overtime compensation with the Department of Labor on August 8, 1957, and March 18, 1958. These filings, which had not yet been acted upon when the instant case was filed, had the effect of interrupting the prescriptive period provided by Section 7-a of Republic Act 1993. The Court clarified that the filing of such claims with the proper office authorized to act thereon serves to suspend the running of the prescriptive period, preventing the claim from being barred by prescription.
Main Doctrine
The Court of Industrial Relations has jurisdiction over claims for overtime compensation if an employer-employee relationship still exists, even without a prayer for reinstatement. Filing claims with the Department of Labor interrupts the prescriptive period.