PVTA vs CIR

G.R. No. L-32052

65 SCRA 416

July 25, 1975

Petitioner: Philippine Virginia Tobacco Administration

Respondent: Court of Industrial Relations 

FACTS: Private respondents filed a petition seeking relief for their alleged overtime services (in excess of their 8 regular hours a day) and the failure to pay for said compensation in accordance with Commonwealth Act No. 444.

• Section 1: The legal working day for any person employed by another shall not be of more than eight (8) hours daily.

Petitioner denies allegations for lack of a cause of action and jurisdiction. 

Respondents filed a Petition for Certiorari on grounds that the corporation is exercising governmental functions and is therefore exempt from CA No. 444 which was denied and dismissed by RTC and CA. Motion for Reconsideration were also DENIED.

ISSUE: Whether or not PVTA discharges governmental and not proprietary functions and is exempt from CA No. 444.

HELD: It is an inherent state function which makes government required to support its people and promote their general welfare. This case explains and portrays the expanded role of government necessitated by the increased responsibility to provide for the general welfare.

The Court held that the distinction and between constituent and ministrant functions, which the Chief Justice points out, is already irrelevant considering the needs of the present time. He says that "The growing complexities of modern society have rendered this traditional classification of the functions of government obsolete." The distinction between constituent and ministrant functions is now considered obsolete. 

The Court affirms that the Petition as well as the subsequent Motion for Reconsideration be DENIED. 

• Constitutional Law 1: State Functions / Concept of State (Constituent and Ministrant) (Textbook: Cruz, Professor, Atty. Usita)

♥ Reese Corpuz