CONSTI 1: CONCEPT OF THE STATE

CASE DIGESTS
“So that in all things, God may be glorified” cite Section 2 of the Act, but its very language
leaves no doubt that "it shall apply to all
PHILIPPINE VIRGINIA TOBACCO ADMIN vs persons employed in any industry or
CIR occupation, whether public or private . . ."
Facts:

 Dec 20, 1966 CIR filed with respondent court a 3. Appealed order and resolution of respondent
petition wherein they alleged that PVTA failed court affirmed. Chief of examining division is to
to pay them overtime compensation in make a reexamination of records, papers, and
accordance to CA 444. documents in the possession of PVA and to
 PVTA denied allegations and raising special submit to the court the findings. This case is
defenses of lack of a cause of action and lack of referred to Nat’l Labor Relations Commission
jurisdiction for further proceedings.
 Respondent court issued an order sustaining
claims of CIR and directing petitioner to pay
the same minus what had already been paid.
Motion for recon but respondent court denied,
hence petition for certiorari
Petitioner’s Argument:

 Plea of reversal of order on basic proposition

that it is beyond the jurisdiction of respondent
Court as it is exercising governmental functions
and is exempt from operation of CA 444
 Eight hour law does not apply to it
Issues:
1. WON petitioner discharges governmental and
not proprietary functions
2. WON petitioner needs to pay the overtime work
of the respondents in accordance to eight hour
labor law
Ruling:
1. As originally established in RA 2265 and RA
4155 makes it evident it is a governmental
agency. However, the success that came along
with the efforts of the petitioner to be adjudged
as performing governmental rather than
proprietary functions cannot militate against
respondent Court assuming jurisdiction over
labor dispute.
(NARIC v. Alvendia) Eight-Hour Labor Lawruled
that it is precisely respondent Court and not ordinary
courts that should pass upon that particular labor
controversy
2. Contention of petitioner about 8 hr law does not
apply to it hardly deserves consideration. It did
*locus standi-ability of party to demonstrate to the Court harm from the law in question