PVTA v CIR Digest

Facts:
This case involves the expanded role of the
government necessitated by the increased responsibility to provide for the general welfare.
1. In 1966 private respondents filed a petition seeking relief for their alleged overtime
services and the petitioner’s failure to pay for said compensation in accordance with CA No.
444.
2. Petitioner denied the allegations for lack of a cause of cause of action and lack of
jurisdiction. Judge Martinez issued an order, directing petitioner to pay. Hence, this petition
for certiorari on grounds that the corporation is exercising governmental functions and is
therefore exempt from Commonwealth Act No. 444.
3. PVTA contended it is beyond the jurisdiction of respondent Court as it is exercising
governmental functions and that it is exempt from the operation of Commonwealth Act No.
444.

Issue: Whether or not PVTA discharges governmental and not proprietary functions.

YES. But the distinction between the constituent and ministrant functions of the government has
become obsolete. The government has to provide for the welfare of its people. RA No. 2265 providing
for a distinction between constituent and the ministrant functions is irrelevant considering the needs of
the present time: “The growing complexities of modern society have rendered this traditional
classification of the functions of government obsolete.”

The contention of petitioner that the Labor Code does not apply to them deserve scant consideration.
There is no question based on RA 4155, that petitioner is a governmental agency. As such, the
petitioner can rightfully invoke the doctrine announced in the leading ACCFA case. The objection of
private respondents with its overtones of the distinction between constituent and ministrant functions
of governments as set forth in Bacani v. Nacoco, is futile. It does not necessarily follow, that just
because petitioner is engaged in governmental rather than proprietary functions, that the labor
controversy was beyond the jurisdiction of the now defunct respondent Court. Nor is the objection
raised that petitioner does not come within the coverage of the Eight-Hour Labor Law persuasive.

A reference to the pertinent sections of both Republic Acts 2265 and 2155 renders clear the
differentiation that exists. If as a result of the appealed order, financial burden would have to be borne
by petitioner, it has only itself to blame. It need not have required private respondents to render
overtime service. It can hardly be surmised that one of its chief problems is paucity of personnel. That
would indeed be a cause for astonishment. It would appear, therefore, that such an objection based
on this ground certainly cannot suffice for a reversal. To repeat, respondent Court must be sustained.