Manila Mandarin v.

NLRC
Facts:
Manila Mandarin Employees Union filed with the NLRC Arbitration Branch a complaint to
compel MANDARIN to pay the salary differentials of certain employees concerned, due to the
wage distortions created by the upward revisions of the minimum wage due to various
Presidential Decrees and Wage Orders, and for MANDARINs failure to implement said
increases.
Issue:
Are the UNIONs members all entitled to a wage increase as well, in view of the alleged wage
distortion resulting from various Presidential Decrees and Wage Orders?
Ruling:
Wage distortions have often been the result of government-decreed increases in minimum
wages. Should a wage distortion exist, correction thereof may be done by re-establishing a
substantial or significant gap between the wage rates of the differing classes of employees.
As a rule, findings in labor cases, where grounded on substantial evidence, are not reviewed by
the Court. However, a disharmony such as exists here, between the factual finding of the Labor
Arbiter and those of the NLRC, opens the door to a review thereof by this Court.
The apparent intention of the law is only to upgrade the salaries/wages of the employees
receiving lower than the minimum daily wage set therein. There were no across-the-board
increases to all employees; increases were required only as regards those specified in the
issuances. The Union was therefore incorrect to claim that all its members were automatically
entitled to increases.
Even if there were wage distortions, which is not the case here, the appropriate remedy
prescribed is for the employer & the union to first negotiate to correct them. If the dispute be
not resolved, the grievance procedure in the CBA, or through conciliation or arbitration would
be the proper remedy.