G.R. No. L-27773 December 28, 1970
EMILIA DE VERA VDA. DE HALILI, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and HALILI BUS DRIVERS and CONDUCTORS UNION — PTGWO, respondents.

FACTS

This case involves a petition for review on appeal by certiorari of an order dated April 27, 1967, and an en banc resolution dated May 25, 1967, from the Court of Industrial Relations (CIR) in Case No. 1099-V. The case originated from a petition filed by the Halili Bus Drivers and Conductors Union (PTGWO) against Fortunato F. Halili (Halili Transit) for violation of Commonwealth Act No. 444 (Eight-Hour Law), alleging non-payment for compensable hours of work such as time for refueling, moving buses from the carbarn, trip intervals, and minor repairs. The CIR, in a decision dated August 7, 1961, found Halili guilty and ordered the computation of compensable hours worked by union members from October 1, 1956, at specified hourly rates. This decision was affirmed with modifications by the CIR en banc on April 6, 1962, and later upheld by the Supreme Court in G.R. No. L-24864 on February 26, 1968, which directed the CIR to judicially determine union membership of the claimants and proceed with the computation. During the pendency of these proceedings, Fortunato F. Halili died on December 29, 1966. The union moved for the substitution of his legal representative. The petitioner, Emilia de Vera Vda. de Halili, was appointed special administratrix (and later regular administratrix) of Halili’s estate. She opposed the substitution, arguing that the money claim should be dismissed and prosecuted in the intestate proceedings. The CIR, in its order of April 27, 1967, appointed and substituted petitioner as the legal representative of the deceased and directed a commissioner to continue receiving evidence on union membership. Petitioner’s motion for reconsideration was denied by the CIR en banc on May 25, 1967.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion or acted without jurisdiction in appointing and substituting the petitioner as the legal representative of the deceased Fortunato F. Halili and in ordering the continuation of the proceedings for the determination of the union membership of the claimants and the computation of their monetary claims.

RULING

The Supreme Court affirmed the order and resolution of the Court of Industrial Relations. The Court held that the CIR did not commit grave abuse of discretion or act without jurisdiction. The ruling emphasized that claims for unpaid wages and overtime pay, being monetary claims that survive the death of the employer, can and should be continued against the legal representative of the deceased’s estate. The Court cited previous jurisprudence, including Philippine Airlines, Inc. vs. Balanguan, which established that money claims for wages under the Eight-Hour Labor Law are actionable against the estate of a deceased employer. The Court rejected the petitioner’s argument that the claim should be prosecuted solely in the intestate proceedings, noting that it would be a useless repetition to retry a claim already adjudicated by a competent court. The CIR was therefore correct in ordering the substitution and in directing the continuation of the proceedings to determine union membership and compute the amounts due, as mandated by the Supreme Court’s prior decision in G.R. No. L-24864. Costs were imposed against the petitioner.