The petitioner PVTA argued it was exempt from paying overtime compensation under Commonwealth Act No. 444 because it performed governmental functions. The court rejected this argument, finding that PVTA could invoke the expanded role of government to provide for public welfare. While PVTA served governmental functions, the distinction between constituent and ministrant functions was obsolete. PVTA was still subject to labor laws regarding overtime pay.
The petitioner PVTA argued it was exempt from paying overtime compensation under Commonwealth Act No. 444 because it performed governmental functions. The court rejected this argument, finding that PVTA could invoke the expanded role of government to provide for public welfare. While PVTA served governmental functions, the distinction between constituent and ministrant functions was obsolete. PVTA was still subject to labor laws regarding overtime pay.
The petitioner PVTA argued it was exempt from paying overtime compensation under Commonwealth Act No. 444 because it performed governmental functions. The court rejected this argument, finding that PVTA could invoke the expanded role of government to provide for public welfare. While PVTA served governmental functions, the distinction between constituent and ministrant functions was obsolete. PVTA was still subject to labor laws regarding overtime pay.
The petitioner PVTA argued it was exempt from paying overtime compensation under Commonwealth Act No. 444 because it performed governmental functions. The court rejected this argument, finding that PVTA could invoke the expanded role of government to provide for public welfare. While PVTA served governmental functions, the distinction between constituent and ministrant functions was obsolete. PVTA was still subject to labor laws regarding overtime pay.
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The contention of petitioner that the Labor Code does not
PVTA v CIR Digest apply to them deserve scant consideration.
Facts: There is no question based on RA 4155, that petitioner is a This case involves the expanded role of the governmental agency. As such, the petitioner can rightfully government necessitated by the increased responsibility to invoke the doctrine announced in the leading ACCFA case. provide for the general welfare. The objection of private respondents with its overtones of the 1. In 1966 private respondents filed a petition distinction between constituent and ministrant functions of seeking relief for their alleged overtime services and governments as set forth in Bacani v. Nacoco, is futile. It does the petitioner’s failure to pay for said compensation in not necessarily follow, that just because petitioner is engaged accordance with CA No. 444. in governmental rather than proprietary functions, that the labor controversy was beyond the jurisdiction of the now 2. Petitioner denied the allegations for lack of defunct respondent Court. Nor is the objection raised that a cause of cause of action and lack of petitioner does not come within the coverage of the Eight- jurisdiction. Judge Martinez issued an order, directing Hour Labor Law persuasive. petitioner to pay. Hence, this petition for certiorari on grounds that the corporation is exercising A reference to the pertinent sections of both Republic Acts governmental functions and is therefore exempt from 2265 and 2155 renders clear the differentiation that exists. If Commonwealth Act No. 444. as a result of the appealed order, financial burden would have 3. PVTA contended it is beyond the jurisdiction of to be borne by petitioner, it has only itself to blame. It need respondent Court as it is exercising governmental not have required private respondents to render overtime functions and that it is exempt from the operation of service. It can hardly be surmised that one of its chief Commonwealth Act No. 444. problems is paucity of personnel. That would indeed be a cause for astonishment. It would appear, therefore, that such Issue: Whether or not PVTA discharges governmental an objection based on this ground certainly 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.”