G.R. No. L-19945 December 29, 1966
NATIONAL MARKETING CORPORATION, petitioner, vs. PRISCO WORKERS UNION, ET AL., and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The case involves a petition for review of a Court of Industrial Relations (CIR) order extending the benefits of its prior decisions to additional employees of the National Marketing Corporation (NAMARCO). The background stems from CIR Case 840-V, originally filed by the Prisco Workers Union against the Price Stabilization Corporation (PRISCO). On August 25, 1953, the CIR rendered a partial decision ordering PRISCO to pay 25% additional compensation for unpaid overtime, Sunday, and legal holiday work from June 8, 1951. This benefit was later extended to other similarly situated PRISCO workers. PRISCO was abolished by Republic Act No. 1345 , which created NAMARCO and transferred PRISCO’s employees and assets to it. Subsequently, on May 20, 1960, the CIR issued an order directing NAMARCO to pay the employees listed in an annex (Annex A) for Sunday, legal holiday, and night work, implementing the 1953 and 1955 decisions. Later, on January 10, 1961, the respondent Union filed a new petition (Case 840-V[9]) seeking to extend the benefits of the May 20, 1960 order to another set of NAMARCO employees listed in an Annex A-1. NAMARCO opposed, arguing the claims had prescribed under Republic Act No. 1993 (amending the Eight-Hour Labor Law), that there was no employer-employee relationship with some claimants who were General Auditing Office (GAO) personnel, and that the judgments could no longer be enforced after five years. The CIR, on March 30, 1962, and affirmed en banc on June 18, 1962, granted the petition, ruling it was a continuation and implementation of the original case, thus not prescribed, and that the GAO employees were similarly situated and entitled. NAMARCO appealed.

ISSUE

1. Are the employees listed in Annex A-1 entitled to the benefits granted by the CIR decisions of August 25, 1953 and June 10, 1955?
2. Have their claims for overtime and Sunday and legal holiday work prescribed?

RULING

1. The Supreme Court affirmed the CIR order extending benefits to the employees and workers of NAMARCO listed in Annex A-1. The Court held that the petition in Case 840-V(9) was a continuation of the original case and an implementation of the prior decisions, not a new cause of action. The benefits of the earlier decisions were intended for all similarly situated employees, not just the original petitioners.
2. The Court held the claims had not prescribed. The petition sought implementation of final and executory decisions (August 25, 1953 and June 10, 1955), and such enforcement is not subject to the three-year prescriptive period under Republic Act No. 1993 .
However, the Court reversed the CIR regarding the GAO employees. It held that GAO personnel assigned to NAMARCO are not corporate employees of NAMARCO; no employer-employee relationship exists. They are agents of the government, appointed and supervised by the Auditor General. Furthermore, they are not covered by the Eight-Hour Labor Law but by the Revised Administrative Code, which prohibits additional compensation for overtime work for those with salaries fixed by law. Therefore, GAO employees are not entitled to recover overtime compensation from NAMARCO.
The dispositive portion affirmed the CIR orders insofar as they extended benefits to NAMARCO employees but reversed and set them aside with respect to the GAO employees.