PEOPLE'S HOMESITE AND HOUSING CORPORATION (PHHC) vs. COURT OF INDUSTRIAL RELATIONS (CIR) [G.R. No. L-31890; May 29, 1987]

Facts:

       The PHHC seeks a reversal of the Resolution of the CIR en banc in ordering them to pay private respondents wage differential for work. The Philippine government and World Food Program (WFP) entered into an agreement in a plan for the Sapang Palay resettlement area in the PHHC proposing a self-help project to be undertaken by the squatter families for the construction of two dams. The undertaking is for the purpose of water irrigation to be used for additional food production. In recruiting participants to the program, the WFP issued an application form mentioning the voluntary nature of the work to be rendered. The participants were assigned to work on canals and roads; however, the projects agreed between the PHHC and WFP were never fully implemented. They were ordered to accomplish a time sheet which is the basis for the payment of 50 centavos/day and a weekly food ration. They were also provided with work tools and assigned a work supervisor to manage and administer the Sapang Palay project in which the latter also conducted ocular inspection in the area. However, the participants went to the Department of Labor complaining about their work and compensation which Secretary Ople suggest that the workers in the said project must be paid in minimum wage law. After that, petitioner suspended work and the workers assert their minimum wage and the 50 centavos be paid to them. The petitioner answered before the CIR that they were exercising governmental functions and that they did not hire private respondents and CIR had no jurisdiction over them. The Court dismissed the action of the petitioner since there was no evidence that private respondents rendered overtime work. The petitioner moved to reconsider before the CIR but denied the claims. Thus, they elevated the case to the Supreme Court.

Issue:

       Whether or not the CIR has jurisdiction over PHHC, a government owned and/or controlled corporation performing governmental function.

Held:

       The Court ruled that the Court of First Instance had jurisdiction over labor disputes involving GOCC but not the performing governmental functions. Since the National Housing Association was created, the Philippine government has carried mass housing and resettlement program to meet the needs of Filipinos. The PHHC is governmental institution performing governmental functions. Thus, the Court grant the petition and set aside the assailed resolution of the Court of CIR.