Manila Terminal Company v. La Corte de Relaciones Industriales
REITERATIONFacts
The Antecedents: The Manila Terminal Relief & Mutual Aid Association filed a petition with the Court of Industrial Relations (CIR) seeking payment for overtime work, work on Sundays and official holidays, and additional compensation from the Manila Terminal Company, Inc. The company, engaged in receiving, delivering, and guarding cargo at the Manila piers, employed special policemen to secure these goods. Procedural History: The company filed two motions to dismiss. The first, based on lack of cause of action, was withdrawn. The second motion, based on the CIR's alleged lack of jurisdiction over the matter, is the subject of this resolution. The company contended that the special policemen were not industrial laborers but members of the Manila Police Force, thus public officers who could not legally go on strike, a prerequisite for CIR jurisdiction under Commonwealth Act No. 103. The Petition: The core of the dispute was the classification of the special policemen: whether they were public officers or industrial employees. The company argued that as public officers, they were outside the CIR's jurisdiction, and therefore, no industrial dispute existed. The association countered that the company's business was private, not governmental, and that the special policemen were paid by and employed by the private company, making them industrial employees.
Issue(s)
Whether the Court of Industrial Relations has jurisdiction over the dispute involving special policemen. Whether the special policemen employed by the Manila Terminal Company, Inc. are public officers or industrial employees.
Ruling
The petition is dismissed. The Court of Industrial Relations has jurisdiction over the dispute. The special policemen are considered industrial employees, not public officers.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations: The Court held that all the requirements for the CIR to acquire jurisdiction under Commonwealth Act No. 103, as amended, were present in this case. The fact that the special policemen were appointed by the Mayor of Manila and sworn in did not divest the CIR of its jurisdiction. The law, as amended, does not provide any exception for this class of employees. The Court considered the petitioners as simple industrial employees because they were employed by and paid by a private corporation, and thus performed their duties without any official character. They were not considered public officers as they were not in the service of the Philippine Government. The company's theory that a strike or the threat of a strike is an indispensable requirement for the CIR's jurisdiction was deemed untenable in this context, as the special policemen were viewed as industrial employees. On the classification of special policemen: The Court concluded that the special policemen are not public officers. While they were appointed by the Mayor of Manila, this was an arrangement to allow them to make arrests within the company's operational radius and to ensure the vigilance of the cargo entrusted to the company, especially given the post-liberation conditions of disorder in the Manila port. The salaries of these special policemen were entirely defrayed by the Manila Terminal Company, Inc., and their services were exclusively rendered within the company's premises. The Court reasoned that if these special policemen were to be considered public officers solely due to their emergency appointments, they would be placed in a disadvantageous position compared to other company employees who could avail themselves of their rights as laborers, including the right to strike. This outcome would contradict the government's policy of social justice. The Court cited precedents, including a CIR case and a National Labor Relations Board case (Bendix Products Corporation), which held that employees paid by a private company, even if commissioned as special officers, are still considered employees of that company.
Main Doctrine
Special policemen appointed by the Mayor of Manila at the instance of a private company, whose salaries are paid by the company and whose services are confined to the company's premises, are considered industrial employees and not public officers, thus falling within the jurisdiction of the Court of Industrial Relations for labor disputes.