PVTA v. CIR, 65 SCRA 416.

Block A:
The Province of North Cotabato v. The

1. Princess Doloiras Government of the Republic of the Philippines
2. Rei Florence Nazarrea Peace Panel on Ancestral Domain, G.R. No.
183591, October 14, 2008, 568 SCRA 402.
3. Pauline Perez Magallona v. Ermita, G.R. No. 187167, August
4. James Joshua Azas 16, 2011,
655 SCRA 476. In relation to RA 9522
5. Jamaine Flores PVTA v. CIR, 65 SCRA 416.
6. Jojemar Enciso In relation to the ruling in ACCFA v. Federation
of Labor Unions, 30 SCRA 649.
Oposa v. Factoran, G.R. No. 101083, 30 July
7. Marivic Fungo 1993, 224 SCRA
8. Paul John Pacheco 792 & Cabanas u. Pilapil, 58 SCRA 94– in
relation to functions of government and the
Doctrine of Parens Patriae
Lawyer's League for a Better Philippines v.
9. Angel Paliza Corazon C.
10. Maria Emily D. Gamos Aquino, G.R. No. 73748, May 22, 1986 &
Peralta v. Director of Prisons, 75 Phil. 285 ( De
Jure and De Facto Governments; Sovereignty)
 PVTA v. CIR, 65 SCRA 416.

In relation to the ruling in ACCFA v. Federation of Labor Unions, 30 SCRA 649.
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.
ACCFA v CUGCO Digest
G.R. No. L-21484 November 29, 1969
Facts:
1. ACCFA, a government agency created under RA 821, as amended was reorganized and its name
changed to Agricultural Credit Administration (ACA) under the RA 3844 or Land Reform Code. While ACCFA
Supervisors' Association (ASA) and the ACCFA Workers' Association (AWA), are labor organizations (the
Unions) composed of the supervisors and the rank-and-file employees in the ACCFA.
2. A CBA was agreed upon by labor unions (ASA and AWA) and ACCFA. The said CBA was supposed to
be effective on 1 July 1962. Due to non-implementation of the CBA the unions held a strike. And 5 days later,
the Unions, with its mother union, the Confederation of Unions in Government Corporations and Offices
(CUGCO), filed a complaint against ACCFA before the CIR on ground of alleged acts of unfair labor practices;
violation of the collective bargaining agreement in order to discourage the members of the Unions in the
exercise of their right to self-organization, discrimination against said members in the matter of promotions
and refusal to bargain.
3. ACCFA moved for a reconsideration but while the appeal was pending, RA 3844 was passed which
effectively turned ACCFA to ACA. Then, ASA and AWA petitioned that they obtain sole bargaining rights with
ACA. While this petition was not yet decided upon, EO 75 was also passed which placed ACA under the Land
Reform Project Administration. Notwithstanding the latest legislation passed, the trial court and the
appellate court ruled in favor of ASA and AWA.
ISSUE: W/N ACA is a government entity
YES.
It was in furtherance of such policy that the Land Reform Code was enacted and the various agencies, the
ACA among them, established to carry out its purposes. There can be no dispute as to the fact that the land
reform program contemplated in the said Code is beyond the capabilities of any private enterprise to
translate into reality. It is a purely governmental function, no less than, the establishment and maintenance
of public schools and public hospitals. And when, aside from the governmental objectives of the ACA, geared
as they are to the implementation of the land reform program of the State, the law itself declares that the
ACA is a government office, with the formulation of policies, plans and programs vested no longer in a Board
of Governors, as in the case of the ACCFA, but in the National Land Reform Council, itself a government
instrumentality; and that its personnel are subject to Civil Service laws and to rules of standardization with
respect to positions and salaries, any vestige of doubt as to the governmental character of its functions
disappears.
The growing complexities of modern society, however, have rendered this traditional classification of the
functions of government quite unrealistic, not to say obsolete. The areas which used to be left to private
enterprise and initiative and which the government was called upon to enter optionally, and only "because it
was better equipped to administer for the public welfare than is any private individual or group of
individuals,"5continue to lose their well-defined boundaries and to be absorbed within activities that the
government must undertake in its sovereign capacity if it is to meet the increasing social challenges of the
times. Here as almost everywhere else the tendency is undoubtedly towards a greater socialization of
economic forces. Here of course this development was envisioned, indeed adopted as a national policy, by
the Constitution itself in its declaration of principle concerning the promotion of social justice.
The Unions have no bargaining rights with ACA. EO 75 placed ACA under the LRPA and by virtue of RA 3844
the implementation of the Land Reform Program of the government is a governmental function NOT a
proprietary function. Being such, ACA can no longer step down to deal privately with said unions as it may
have been doing when it was still ACCFA. However, the growing complexities of modern society have
rendered the classification of the governmental functions as unrealistic, if not obsolete. Ministerial and
governmental functions continue to lose their well-defined boundaries and are absorbed within the activities
that the government must undertake in its sovereign capacity if it to meet the increasing social challenges of
the times and move towards a greater socialization of economic forces.

PVTA v. CIR, 65 SCRA 416.

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Block A:

The Province of North Cotabato v. The

 PVTA v. CIR, 65 SCRA 416.

G.R. No. L-32052

Petitioner: Philippine Virginia Tobacco Administration

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

ISSUE: Whether or not PVTA discharges governmental and not proprietary functions

ACCFA v CUGCO Digest

G.R. No. L-21484 November 29, 1969

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