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LABOR Digests 100215 1.

Whether or not the one retirement plan

constitutes a diminution of benefits
Wesleyan v. Wesleyan proscribed by Art. 100 LC.
Metrobank v. NLRC 2. Whether or not the memorandum on
Sugue v. Triumph vacation and sick leave is valid.
Aklan Electric v. NLRC
Univ of Pangasinan Faculty v. Univ of Pang III. Held/Ratio:
Intl School Alliance v. Quisumbing
Legent Hotel v. Realuyo 1. YES. The one retirement plan is void for
Phil Fisheries v. NLRC being contrary to the rule on non-
Iran v. NLRC diminution of benefits, as their previous
Millares v. NLRC two retirement plan had already ripened to
SLL INtl Cables v. NLRC a company practice that may be protected
One Haus Realty v. Parien under Art. 100 LC.

The petitioners argue that the CBA and PERAA

Plans are one and the same.
WESLEYAN UNIVERSITY PHILS v WESLEYAN UNIVERSITY o There is no established company practice
PHILS. FACULTY AND STAFF ASSOCIATION or policy of giving two retirement benefits
G.R. No. 181806; 12 Mar 2014; DEL CASTILLO, J. to its employees.
Digest by Miguel o Assuming that both were released, these
were done by oversight or mistake as
Doctrine: Art. 100 LC on non-diminution of benefits applies there was no Board Resolution authorizing
when a benefit is expressly provided by company policy, in their release.
the terms of a contract, or in cases where a practice has o As such, these cannot ripen into a
been consistently and deliberately applied by an employer. company practice or policy.
The exception to the rule on practice is when such is due to o The affidavits submitted were self-serving
error in the construction or application of a doubtful or declarations that should not be given
difficult question of law; in this case, the error must be weight.
corrected immediately after its discovery, else Art. 100 o As to the memorandum, it is valid because
would still apply. it is in full accord with existing policy.
The Non-Diminution Rule in Art. 100 LC
I. Facts: prohibits employers from eliminating or
The petitioner and respondents signed a 5- reducing the benefits received by their
year CBA effective Jun 1, 2003 - May 31, 2008. employees.
On Aug 16, 2005, the petitioner, through its o It applies only if the benefit is based
president, Atty. Maglaya, issued a memo on on an express policy, written
the implementation of vacation and sick contract, or has ripened into a
leave credits, and vacation leave practice.
commutation: o To be considered a ripened practice, it
o as to the former, it stated that such credits must be consistently and deliberately
are not automatic-- they must be earned made by the employer over a long period
at a rate of 1.25 days / month, with a of time, except when the practice is due to
maximum of 15 days each; error in the construction or application of a
o as to the latter, only vacation leave is doubtful or difficult question of law; in this
commuted or monetized to cash, after the case, the error must be corrected
second year of continuous service. immediately after its discovery, else Art.
This was questioned by the respondent's 100 would still apply.
President, who wrote a letter informing him The respondents were able to present
of these changes as violative of existing substantial evidence through the affidavits,
practices and the CBA, where the vacation and which showed that management consistently
sick leave accrue automatically, and vacation leave gave two retirement benefits since 1997--
commutes upon the second year of service. these went past unrefuted.
A Labor Management Committee was held during o The argument that the affidavits are self-
which the respondent was advised to file a serving holds no water as the retired
grievance complaint. employees have nothing to lose/gain as
In the same meeting, however, the petitioner they already received their benefits-- they
announced its plan of implementing a one- have no reason to perjure themelves, and
retirement policy, which was unacceptable to simply wanted to bring out the truth.
the respondent as they had two retirement o Along with the affidavits of incumbent
benefits, one from the PERAA and another from the employees, it shows that the granting of
CBA, which was evidenced by the CBA and two retirement benefits has already
affidavits. ripened into a practice.
The Voluntary Arbitrator held that both the Further, the petitioners were unable to show
one-retirement policy and memorandum are that there was only one retirement plan--
declared contrary to law. The CA affirmed this nothing in the CBA shows that the CBA and
decision. PERAA plans are the same-- such doubt
should be resolved in favor of labor.
II. Issues:

LABOR: Digests | 100215 | kb | 1

o Further, if there was already a one-
retirement policy, why did the petitioner It is Metrobanks position that the CA and the NLRC erred
have to make the announcement? when they recognized that there was an established
o Worse, there was a letter-memo prepared company practice or policy of granting improved
by their legal counsel that sought benefits to its officers effective January 1 of the year
suggestions on how to justify the abolition and without any condition that the officers should remain
of the double retirement policy. employees of Metrobank as of a certain date. Metrobank
Hence, the two retirement policy is a benefit argues that the same cannot be concluded to have ripened
protected by law. The company made a last- into a company practice since the provisions of the
ditch argument stating that the practice is illegal or retirement plan itself and the law on retirement should be
unauthorized, but this was not substantiated by controlling.
RULING AND RATIO: Decision of the CA affirmed.
2. NO. The memorandum is void for being Grant of improved benefits ripened into a company
violative of the clear provisions of the CBA. practice which cannot be unilaterally withdrawn by
o The memorandum effectively limits the available the employer without violating Art. 100 of the LC.
leave credits of an employee at the start of the - To be considered a company practice, the giving of
school year, from 15 to 5 (during the first four the benefits should have been done over a long
months). period of time, and must be shown to have
o It imposes a limitation that was not agreed upon by been consistent and deliberate. The test or
the parties nor stated in the CBA. rationale of this rule on long
o When the provisions in the CBA are clear, leaving practice requires an indubitable showing that
no doubt as to the intent of the parties, the literal the employer agreed to continue giving the
meaning of the stipulation shall govern, and in benefits knowing fully well that said
case of doubt, resolve in favor of labor. employees are not covered by the law
requiring payment thereof.
- It was the NLRCs finding, as affirmed by the CA,
Metrobank v. NLRC that there is a company practice of paying
June 18, 2009; J. Leonardo-De Castro improved benefits to petitioner banks officers
effective every January 1 of the same year the
Facts: improved benefits are granted to rank and file
- Private Respondents: Felipe Patag and Bienvenido employees in a CBA. We find that the NLRCs and
Flora were former employees of Metrobank CAs factual conclusions were fully supported by
o Availed of the banks compulsory substantial evidence on record.
- Evidence presented: Previous 4 CBAs did not have
retirement plan
the condition that the benefits shall only be
o As of Feb 1, 1998 (Time of Compulstory
extended to those who remain in service as of June
Retirement): Patag was an Assistant
15, 1998
Manager with a monthly salary of PhP32k
o Condition was imposed for the first time in
o April 1, 1998 (Time of Compulsory
the 1998 CBA
Retirement): Flora was a Senior Manager
o This shows that Metrobank consistently,
with a monthly salary of PhP48.5k
deliberately and voluntarily granted
o Both received their respective retirement
improved benefits to its officers, after the
benefits at 185% of their gross monthly
signing of each CBA with its rank and file
salary for every year of service[Patag:
employees, retroactive to January 1st of the
PhP 1.9M; Flora: PhP 3M]
same year as the grant of improved
- CBA for 1998-2000: Increased retirement
benefits and without the condition that the
benefit from 185% to 200% of his gross monthly
officers should remain employees as of a
salary for every year of service
certain date
o Effectivity to retroact to January
o The court held, in these cases, that the
grant of benefits through time has
o BUT, with the condition that the
ripened into company practice which
benefits shall only be extended to
those who remain in service as of
June 15, 1998
Davao Fruits v Assoc. Labor Union:
- Patag (+Php 284k) and Flora (+448k) requested
Increase 13th month, maternity
that the new CBA be applied to their retirement
leave pay and cash equivalent of
benefits, but DENIED by Metrobank.
unused VL and SL [lasted for 6
- Respondents filed an action with the Labor Arbiter
against Petitioner for underpayment of retirement
Tiangco v Leogardo : Fixed
benefits and damages
monthly emergency allowance [3
o LA: Dismissed
years and 4 months]
o NLRC: Partially granted (company practice:
Sevila Trading v Semana: Unused
no condition as to the increase)
SL and VL incorporated in the 13 th
o CA: Affirmed the NLRC
month pay [2 years]
Issue: WON Respondents can still recover higher benefits
Common denominator: appears
under the 1998 Officers Benefits Memorandum despite the
fact that they have compulsorily retired prior to the
issuance of said memorandum and did not meet the
condition therein requiring them to be employed as of June
15, 1998?
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- In the case at bar, petitioner Metrobank favorably Held:
adjusted its officers benefits, including retirement 1. The conditions set by the company do not amount to
benefits, after the approval of each CBA with the discrimination. In the grant of vacation and sick leave
rank and file employees, to be effective every privileges to an employee, the employer is given
January 1st of the same year as the CBAs approval, leeway to impose conditions on the entitlement to the
and without any condition regarding the date of same as the grant of vacation and sick leave is not a
employment of the officer, from 1986 to 1997 or standard of law, but a prerogative of management. It is
for about eleven (11) years. This constitutes a mere concession or act of grace of the employer and
voluntary employer practice which cannot be not a matter of right on the part of the employee. Thus,
unilaterally withdrawn or diminished by the it is well within the power and authority of an employer
employer without violating the spirit and intent of to deny an employees application for leave and the
Art. 100 of the Labor Code same cannot be perceived as discriminatory or
o Art. 100. Prohibition against elimination or harassment. Triumph did not act with discrimination,
diminution of benefits. Nothing in this insensibility or disdain towards Sugue and Valderrama,
Book shall be construed to eliminate or in which foreclosed any choice on their part except to
any way diminish supplements, or other forego their continued employment.
employee benefits being enjoyed at the 2. Triumph is justified in charging Sugue and Valderramas
time of promulgation of this Code half-day absence to their vacation leave credits. It is
o Volunteer employer practice = CANNOT BE fair and reasonable for Triumph to do so considering
UNILATERALLY WITHDRAWN without that Sugue and Valderrama did not perform work for
violating the above provision one-half day on June 19, 2000.

Sugue v. Triumph International The age-old rule governing the relation between labor and
G.R. No. 164804; 30 January 2009; Leonardo-De Castro, J. capital or management and employee is that a fair days
Digest prepared by Ron San Juan wage for a fair days labor. If there is no work performed
by the employee there can be no wage or pay, unless of
Facts: course, the laborer was able, willing and ready to work but
Sugue was hired in May 1990 as Marketing Services was illegally locked out, dismissed or suspended. It is
Manager; Valderrama was hired in April 1993 as Direct hardly fair or just for an employee or laborer to fight or
Sales Manager. In October 1999, Triumphs top litigate against his employer on the employers time.
management began to notice a sharp decline in the
sales of the company. In a case where a laborer absents himself from work
In 2000, in a separate case, Sugue and Valderrama because of a strike or to attend a conference or hearing in
filed a complaint with the NLRC against Triumph for a case or incident between him and his employer, he might
payment of money claims arising from allegedly unpaid seek reimbursement of his wages from his union which had
vacation and sick leave credits, birthday leave and declared the strike or filed the case in the industrial court.
14th month pay for the period 1999-2000 (the period Or, in the present case, he might have his absence from his
of the said decline in sales). Triumph charged as half- work charged against his vacation leave.
day to their vacation leave credit their time attending
the preliminary conference of said case.
Thereafter, the applications of both Sugue and Aklan Electric Cooperative Incorporated v NLRC
G.R. No. 121439, January, 25, 2000.
Valderrama for leave credits were subjected to various
Ponente: Gonzaga- Reyes, J. Digester: Roxas
o Sugue complained that the conditions imposed
upon her by the company before granting her
leaves (e.g. medical certificate in the case of
Petitioner: Aklan Electric Cooperative Incorportated
her applications for sick leave and the
submission of the companys marketing plan in
Respondents: NLRC, Retiso and 165 other AKELCO
the case of her applications for vacation leave)
constituted harassment and discrimination
making her work unbearable and, thus,
prompting her to file a complaint with the
NLRC for constructive dismissal against Date Event
Triumph International.
o Valderramas case is similar to that of Sugues. January 22, 1992 AKELCO temporarily transfers holding of
The cited complaints for constructive dismissal office from main office in Lezo, Aklan
was premised on their argument that they (Lezo) to Amon theater, Kalibo, Aklan
were being singled out by the company (Kalibo) on the ground that the office at
because of their earlier filing of money claims Lezo was dangerous and unsafe.
before the NLRC against the company. *it was not explicitly stated what made
the area dangerous and unsafe, but it
Issue: seems like it had something to do with
1. Whether or not the conditions imposed by the company military insurgents
for the granting of leave credits amounted to
discrimination or harassment, supporting the claim of January 31, 1992 Respondents and other workers of
constructive dismissal. (NO) AKELCO engaged in illegal strikes and
2. Whether or not Triumph is justified in charging their refused to report for work in Kalibo, but
absence (due to attending the preliminary conference continuously reported for work in Lezo.
in the NLRC) to their Vacation Leave (YES)

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AKELCO is now appealing the decision of the NLRC, alleging
Date Event
grave abuse of discretion under rule 65.
Feb 6, 1992 NEA administrator wrote a letter to the
Provincial police chief of Kalibo Aklan,
1. WON respondent workers refused to work under
requesting for military assistance to aid
the lawful orders of petitioner AKELCO. Yes, workers
AKELCOs team in retrieving equipment
refused lawful orders.
and facilities, and its transfer from Lezo
2. WON respondent workers are covered by the no
to Kalibo and to maintain peace and
work, no pay principle and are not entitled to unpaid
order in the covered area.
wages from June 1992 - March 1993. Yes, not entitled to
NEA administrator wrote to AKELCO
board saying that he is not interposing
any objections to the transfer of office.
Respondents unjustly refused to render services from June -
March 1993, thus, they are not entitled to payment of
Feb 11, 1992 Respondent workers, claim that the wages for that period.
board passed an unumbered resolution
withdrawing the temporary designation Ratio:
of office at Kalibo and returning daily
operations to Lezo. Transfer of office from Lezo to Kalibo justified.
- SC found that this resolution was
Office was unsafe and posed a serious and
inexistent, as it was contrary to the
imminent threat to AKELCO officials and employees
subsequent resolutions passed.
o Transfer of office was done upon
recommendation of Atty. Mationg, the
Sept 9, 1992 Resolution #411. AKELCO board
project supervisor, on the ground that Lezo
dismissed all employees including
was unsafe.
respondents who were on illegal strike,
o The transfer was then approved by NEA
and refused to report for work at Kalibo
office, since January 31, 1992, despite administrator. Who subsequently
NEA directive. requested for military assistance from the
provincial police chief.
o Obviously the operation of business in
March 1993 AKELCO returns operations to main Lezo posed a serious and imminent threat.
office in Lezo. Transfer of office was done in the exersice of a
management perogative
March 10, 1993 Resolution #477 AKELCO allows o It is withint the right of
Respondent workers who were management to move its operations.
dismissed in the previous resolution to o In the absence of evidence showing that
return to the company out of the transfer is unjustified, it is presumed a
compassion, reconciliation, Christian valid exersice of management perogative.
values and humanitarian reason, subject
to the condition of no work, no pay
NLRC wrongly found that respondent workers rendered
June, 1993 Respondent workers,demanded for the services from June to March.
payment of back wages from June 1992 NLRCs finding that respondent workers had
- March 1993. rendered services from June to March was based
June 4, 1993 Resolution #496 AKELCO rejects the 1. Letter of Leyson, office manager of
demands of respondent workers for AKELCO requesting for payment of
unpaid wages from June 16, 1992 - respondents unpaid wages.
March 1993. 2. Memorandum of Atty. Mationg, in answer
to the aforementioned letter of Leyson,
assuring Leyson that his request for
- Following the timeline, respondent workers, were payment of wages would be recommended
not working in AKELCO, Kalibo from January 31, 1992 until to the board.
the time they were allowed to return to the company in 3. Respondent workers own computation of
March 10, 1993. their unpaid wages.
- They are however, only claiming that the company
The aforementioned evidence is not substantial
failed to pay them for services rendered from June 1992-
enough. It did not establish that they in fact
March 1993.
rendered services in the Kalibo office during said
- Respondents are not claiming wages for the period
from January 1992 - May 1992.
1. Leyson, although admittedly an office
manager, is one of the respondent
Ruling of the lower courts:
claiming unpaid wages. His request in
LA: Respondent workers refused to work under lawful
behalf of the others is thus biased and self
orders of AKELCO, hence they are covered by the no work,
no pay principle and are not entitled to claim for unpaid
2. Atty. Mationg did not approved or assure
wages from June 1992- March 1993.
payment of wages. He merely said that he
NLRC: Reversed findings of the LA. Ordered AKELCO to pay
would recommend payment, further
subject to the approval of the board of
directors, if the funds were available.
LABOR: Digests | 100215 | kb | 4
year and there were no actual services rendered during the
Feb 11, 1992 unumbered resolution was not a valid act of
AKELCOs legitimate board, considering the subsequent During AY 1981-82, UNIVERSITY was authorized by the
actions taken by the board. Ministry of Education and Culture to collect a 15% increase
of tuition fees. UNION members demanded a salary
Respondents did not work during the period in question increase to be taken from 60% of the incremental proceeds.
Having established that the office was validly UNIVERSITY refused, though it did grant a 5.86% salary
transfered it was incumbent upon respondent increase during the pendency of the proceedings.
workers to prove that they had rendered services,
its a basic rule that each party must prove their Some UNION members were also given extra loads to
affirmative allegations. handle in the said school year but were unable to teach on
o Respondents merely relied on their own 21 September 1981 due to said day being proclaimed a
computations as evidence. There must be working holiday by the President. Those with teaching loads
competent proof such as time cards or claimed they were not paid salaries while UNIVERSITY
office records to show that they actually claimed they were paid.
rendered office service. The case does not disclose how the lower tribunals ruled.
o It is impossible that they were able to work
in the Lezo office, since all the equipment ISSUES-HELD-RATIO
of AKELCO was moved to the Kalibo office. WON UNION members are entitled to ECOLA during the
Respondents had been dismissed from January 31, sembreak: YES
1992 March 1993 and yet only claimed Presidential Decrees providing for ECOLA (Nos.
backwages for June March. 1614, 1634, 1678, and 1713) provide that
o Respondents claim that they had employees shall be paid monthly allowance if they
been paid for services rendered by them in incur no absences such that absence without pay
the Lezo office from January June, 1992. shall result in deductions in the allowance while
o They were not however able to rebut leave with pay will not.
petitioners claim that respodents illegally The sembreak, being in the nature of a work
collected fees and charges legally due to interruption beyond the employees control, cannot
AKELCO and appropriated the collections be considered as absences within the meaning of
among themselves to satisfy their salaries the law.
from January to June 1992. The no work, no pay principle does not apply
here as this contemplates a situation where the
No work no pay principle employees voluntarily absent themselves. In this
the age-old rule governing the relation between case, UNION member faculty do not voluntarily
labor and management of a fair days wage for a absent themselves but re constrained to take
fair days labor remains the basic factor in mandatory leave from work.
determining employees wages. UNIVERSITY contends that fact receiving salary, as
If there is no work performed by the employee, UNION members in fact did during the sembreak,
there can be no wage or pay, unless the laborer should not be basis for recovery of ECOLA. The
was willing and able but was illegally locked out or Court disagreed, citing Section 5 of the IRRs for
dimissed. Wage Order No. 1 which provides that all covered
Such exception, is not present in this case. employees are entitled to daily living allowance
It would not be fair nor just to allow respondent when paid their basic wage. Hence, there is the
principle of no pay, no ECOLA the converse of
workers to reconver something they did not near
which is applicable in the present case.
and could not have earned because they did not
render services at Kalibo during the stated period. The payment of full wages during sembreak is a
tacit recognition that teachers are nevertheless,
UNIVERSITY OF PANGASINAN FACULTY UNION burdened with work consisting of papers to correct,
(UNION) v. UNIVERSITY OF PANGASINAN students to evaluate, deadlines to meet, and
(UNIVERSITY) grades to submit. Teachers must keep abreast of
20 February 1984; Gutierrez, J. | Digest Prepared by Hans developments,
Santos Furthermore, applying the Omnibus Rules
FACTS Implementing the Labor Code, the time during
UNION is a labor union composed of faculty members of which the employee is inactive by reason of work
UNIVERSITY. UNION filed acomplaint, though its President, interruption is considered time worked if the
Miss Abad, against the UNIVERSITY for (a) payment of internal is too brief to be utilized effectively and
Emergency Cost of Living Allowances (ECOLA) for 7 gainfully for the employees own interest.
November to 5 December 1981, the semestral break
(sembreak); (b) salary increases from the 60% of WON 60% of proceeds are to be devoted to salary increase:
incremental proceeds of increased tuition fees; and (c) YES
payment of salaries for extra loads. The Court here is called to interpret Section 3 of PD
451, to wit:
UNION members are full-time professors, instructors and
teachers of UNIVERSITY. The teachers in the college level SEC. 3. Limitations. - The increase in tuition or other
teach for a normal duration of 10 mos in a school year, school fees or other charges as well as the new fees or
excluding 2 months of summer vacation. During the charges authorized under the next preceding section shall
sembreak, they were paid their monthly salaries but not be subject to the following conditions:
the ECOLA. UNIVERSITY claims they are not entitled on the a) That no increase in tuition or other school fees or
grounds that the break is not an integral part of the school charges shall be approved unless sixty (60%) per
LABOR: Digests | 100215 | kb | 5
centum of the proceeds is allocated for increase in I. Facts
salaries or wages of the members of the faculty International School, Inc. (the School, for short), pursuant to
and all other employees of the school concerned, Presidential Decree 732, is a domestic educational
and the balance for institutional development, institution established primarily for families of foreign
student assistance and extension services, and diplomatic personnel and other temporary residents.
return to investments: Provided, That in no case
shall the return to investments exceed twelve It hires both foreign and local teachers, the determination
(12%) per centum of the incremental proceeds; x x being a hire's answers to their four way test. 1 A single
x" answer to any of those questions being the Philippines
makes that hire classified as a local hire.
The Court had earlier ruled in University of the
East v. UE Faculty Association that the increase in The School grants foreign-hires certain benefits not
salaries or wages shall not include allowances and accorded local-hires. These include housing, transportation,
benefits which may be taken from the return on shipping costs, taxes, and home leave travel allowance.
investment. Return on investment is fixed at a Foreign-hires are also paid a salary rate twenty-five percent
maximum of 12% but without any minimum. (25%) more than local-hires. The School justifies the
UNIVERSITY contends that this earlier decision difference on two "significant economic disadvantages"
disregards the spirit of the law as the PDs whereas foreign-hires have to endure, namely: (a) the "dislocation
clauses make references to salary and other factor" and (b) limited tenure.
benefits, allegedly implying that the latter is
included in the former. The Court disregarded this The School also argued that there was no
saying that it is an elementary principle of discrimination/equal protection issue here because if a
statutory construction that the whereas clauses foreigner living in the Philippines was hired, he would be
cannot prevail over the statements in the law itself. entitled to the same compensation as Filipino local hires.

The law is clear that the 60% incremental proceeds shall be This difference was brought up during negotiations for new
devoted entirely to increases in basic salary. To charge collective bargaining agreement. Short story: talks broke
other benefits to these proceeds would reduce the increase down, there was a strike, and the DOLE ruled in favour of
in basic salary intended to help the teachers. the School (adopting the School's argument that it needs to
The Court is not guilty of usurpation of legislative use these incentives to be a competitive employer).
functions as it merely interpreted the meaning of
the law within its provisions. The ruling in II. Issues
University of the East was merely to answer the 1. Is the difference in compensation fair?
query of where to charge the said benefits. 2. Do foreign-hires belong in the same bargaining unit as
local hires?
WON payment of salary for 21 September 1981 was proven
by substantial evidence: YES III. Held
1. No. There exists in this jurisdiction the legal truism of
As found by respondent NLRC, the faculty
"equal pay for equal work." Persons who work with
members have been paid for the extra loads. This
substantially equal qualifications, skill, effort and
is a question of fact within the competence of the
responsibility, under similar conditions, should be paid
NLRC to pass upon.
similar salaries.
Assuming that these have not been paid, faculty
members are not entitled thereto applying the no 2. No. To include foreign-hires who have distinct benefits in
work, no pay principle. These are not regular a bargaining unit with local-hires would not assure either
loads for which faculty members are paid regular group the exercise of their respective collective bargaining
monthly salaries regardless of working days or rights.
hours. These are extra loads which should only be
pad when work is actually performed. Since there IV. Ratio
was no work on 21 September 1981, faculty 1. The Court makes a shopping list of laws that prohibit the
members should not be granted extra wages for practice in question (along the argument that it is
that day. discrimination):
a. The Constitution in the Article on Social Justice and
Petition is GRANTED. UNIVERSITY ordered to pay ECOLA Human Rights exhorts Congress to "give highest priority to
and undistributed balance 60% incremental proceeds as the enactment of measures that protect and enhance the
salary increases. NLRC decision SUSTAINED in denying right of all people to human dignity, reduce social,
payment of salary for 21 September. economic, and political inequalities."
b. Article 19 of the Civil Code requires every person, "in the
exercise of his rights and in the performance of his duties,
Intl School Alliance of Educators v. Quisumbing (DOLE) [to] act with justice, give everyone his due, and observe
G.R. No. 128845, 1 June 2000; Kapunan, J. honesty and good faith.
Digest prepared by Jethro Koon
1a. What is one's domicile? b. Where is one's home
In ruling for the teachers, the Court used many economy?
international conventions and covenants. All embody the c. To which country does one owe economic
general principle against discrimination, the very antithesis allegiance?
of fairness and justice. The Philippines, through its d. Was the individual hired abroad specifically to
Constitution, has incorporated this principle as part of its work in the School and was the School responsible for
national laws. bringing that individual to the Philippines?
LABOR: Digests | 100215 | kb | 6
c. The Universal Declaration of Human Rights a. He was paid P400.00 per three hours of
d. International Covenant on Economic, Social, and Cultural performance from 7:00-10:00 pm, 3-6
Rights (Article 7) provides: nights a week. His rate was later increased
- (i) Fair wages and equal remuneration for work of to P750.00.
equal value without distinction of any kind, in particular 2. July 9, 1999, the MANAGEMENT notified REALUYO
women being guaranteed conditions of work not inferior that because they had to cut costs his services
to those enjoyed by men, with equal pay for equal work; were no longer required effective July 30, 1999.
e. International Convention on the Elimination of All Forms 3. REALUYO filed complaint for illegal dismissal,
of Racial Discrimination questioning the grounds of his dismissal since the
f. Convention against Discrimination in Education company was then earning lucratively.
g. Convention (No. 111) Concerning Discrimination in a. But LEGEND raised the defense that there
Respect of Employment and Occupation was no employer-employee
h. The Constitution (Article XIII, Section 3) specifically relationship since REALUYO was only
provides that labor is entitled to "humane conditions of engaged as talent.
work." 4. The LABOR ARBITER ruled in favor of LEGEND
These conditions are not restricted to the physical HOTEL, since REALUYO had admitted in a letter
workplace the factory, the office or the field but that (1) the amounts he was receiving was talent
include as well the manner by which employers treat their fee; and (2) that he was paid nightly and not bi-
employees. monthly like employees of the restaurant. The
i. The Constitution (Article XIII, Section 3) also directs the NLRC affirmed.
State to promote "equality of employment opportunities for 5. The CA reversed and ruled in favor of REALUYO,
all." holding that the four elements of an employer-
j. The Labor Code (Article III) provides that the State shall employee relationship had been met.
"ensure equal work opportunities regardless of sex, race or 6. LEGEND HOTEL filed a petition for review on
creed." certiorari, arguing inter alia that talent fees were
k. The Labor Code (Article 135) prohibits and penalizes the not included in wage under the Labor Code, and
payment of lesser compensation to a female employee as hence were the consideration for their service
against a male employee for work of equal value. Article contract.
248 declares it an unfair labor practice for an employer to
discriminate in regard to wages in order to encourage or B. Issues
discourage membership in any labor organization. These 1. WON the petition for certiorari filed with the CA
show that discrimination in the form of wages is frowned was the proper recourse. YES
upon by the Labor Code. 2. WON there was an employer-employee
The dislocation factor and limited tenure affecting foreign- relationship. YES
hires are adequately compensated by certain benefits 3. WON ROA was validly terminated. NO
accorded them which are not enjoyed by local-hires, such
as housing, transportation, shipping costs, taxes and home C. Held: Petition DENIED, decision of the CA AFFIRMED
leave travel allowances. with MODIFICATION that if reinstatement is no longer
possible, LEGEND HOTEL shall pay backwages and
2. A bargaining unit is "a group of employees of a given separation pay (computed from Sept. 1992).
employer, comprised of all or less than all of the entire 1. YES, the CA is empowered to receive evidence on
body of employees, consistent with equity to the employer, factual issues.
indicate to be the best suited to serve the reciprocal rights 2. YES, the four-fold test has been met; albeit
and duties of the parties under the collective bargaining denominated as talent fees, REALUYOs
provisions of the law." remuneration is included in the term wage in
The factors in determining the appropriate collective the context of the Labor Code.
bargaining unit are (1) the will of the employees (Globe 3. NO, the COMPANY was not able to prove that the
Doctrine); (2) affinity and unity of the employees' interest, retrenchment was justified.
such as substantial similarity of work and duties,
or similarity of compensation and working conditions D. Ratio
(Substantial Mutual Interests Rule); (3) prior collective 1. Certiorari was a proper course. A petition for
bargaining history; and (4) similarity of employment status. certiorari brought to the CA to assail the decision of the
The basic test of an asserted bargaining unit's acceptability NLRC may raise factual issues.
is whether or not it is fundamentally the combination which
will best assure to all employees the exercise of their 2. There was an employer-employee relationship.
collective bargaining rights. Foreign-hires have indicated The power of selection is firmly evidenced by the
no intention to be grouped together with local-hires, nor express written recommendation (dated Jan. 12,
have they been grouped together in the past. The fact that 1998) by the restaurant manager for an increase in
they receive distinct benefits justify their exclusion from the REALUYOs remuneration.
other. o LEGEND cannot hide behind the service
contract. The law defines the relationship.
His remuneration falls under wages in the
Legend Hotel v. Hernani Realuyo sense and context of the Labor Code,
G.R. No. 153511; July 18, 2012; Bersamin, J. regardless of how petitioner chose to
Digest prepared by Paolo Tamase designate the remuneration.
(Heavily borrows, with permission, from Hanss digest) o Art. 97(f) of the Labor Code clearly states
that wage is any remuneration or
A. Facts earnings, however designated, capable of
1. REALUYO, under his stage name Joey R. Roa, had being expressed in terms of money,
been engaged as a pianist in the Legend Hotels whether fixed or ascertained on a time,
Tanglaw Restaurant since September 1992.
LABOR: Digests | 100215 | kb | 7
task, piece, or commission basis, or other Security Supervisor: 2090.00
method of calculating the same, which is Detachment Commander:
payable by an employer to an 2190.00
employee under a written or Such compensation was to include,
unwritten contract of employment for among others, the following: minimum
work done or to be done, or for wage (Wage Order No. 5), rest day
services rendered or to be rendered pay, night differential pay, incentive
xxx leave pay, 13th month pay, emergency
o LEGEND did not present is payroll to cost of living allowance (up to Wage
bolster its claim that REALUYO is not its Order No. 5), 4% contracts tax,
employee. operational expenses, and overhead.
o That REALUYO worked for less than 8 The agreement was also provided for
hours a day was of no consequence; a one-year renewable period.
the Labor Code only set a maximum of 8 - 10/24/87: During the effectivity of said
hours, but did not prohibit work for less Security Agreement, Odin requested the PFDA
than that. to adjust the contract rate in view of Wage
The employer exercises the power of control. Order No. 6, which took effect 11/1/84 (note
o (a) REALUYO could not choose the time of that said wage order had already taken effect
his performance. even before the Security Agreement was
o (b) He could not choose the place of his entered into). This was in line with Sec. 7(c)
performance. of the Security Agreement, which calls for
o (c) He had to conform to the motif by an automatic escalation of the rate per
playing Tagalog songs only, or wearing a guard in case of wage increase. Wage Order
barong. No. 6 provides:
o (d) He was subjected to the rules on SECTION 9. In the case of contracts for construction
employees representation check and projects and for security, janitorial and similar services, the
chits. increases in the minimum wage and allowance rates
o It is suffice that the employer has the right of the workers shall be borne by the principal or
to wield that power. client of the construction/service contractor and the
LEGEND had the power to dismiss. While LEGEND contracts shall be deemed amended accordingly,
claimed that the power to terminate the subject to the provisions of Section 3(c) of this Order.
relationship (at will, and with or without cause) was (emphasis supplied)
mutually vested on both parties, the - This and subsequent requests for adjustment
memorandum informing REALUYO that he has of the contract price were ignored by PFDA.
been fired because of the financial condition of the - 6/7/88: Odin filed with the Office of the Sub-
company showed that it had the power to dismiss. Regional Arbitrator a complaint for unpaid
amount of readjustment rate.
3. The termination was invalid. - 8/19/88: The Labor Arbiter, upon motion of
Retrenchment is an authorized cause under art. PFDA, dismissed Odins complaint, stating that
283 to avoid or minimize business losses, but PFDA was a GOCC under the scope and
LEGEND did not present evidence to prove the jurisdiction of the Civil Service
losses to its business and the economic havoc it Commission, and not the NLRC.
would sustain. - 1/17/89: On appeal, the NLRC set aside the
Labor Arbiters order and granted the reliefs
Not every loss can justify a retrenchment. The loss
requested by Odin.
must be (a) substantial and (b) reasonably
- After the denial of PFDAs motion for
imminent; (3) the retrenchment must be
reconsideration, the instant petition was
reasonably necessary and likely to effectively
brought to the SC.
prevent expected losses; and (4) the alleged losses
must be proved by sufficient and convincing
II. Issues/Ratio
1. W/N the jurisdiction of the Civil Service
Commission may be invoked in this case.
Philippine Fisheries Development Authority v. NLRC
PFDA is a GOCC with a special charter,
and Odin Security Agency
G.R. No. 94825; September 4, 1992; Gutierrez Jr., J. placing it under the scope of the civil
Digest prepared by Carlo Roman service. However, the guards are
not employees of PFDA, it being
I. Facts explicitly stated in the Security
- 11/11/85: Petitioner Philippine Fisheries Agreement that security guards are
Development Authority (PFDA), a GOCC not considered employees of the
created under PD No. 977, entered into a petitioner. Civil Service Commission
Security Agreement with private respondent jurisdiction thus cannot be invoked.
Odin Security Agency for security services of PFDA is therefore an indirect
its Iloilo Fishing Port Complex in Iloilo City. employer of the security guards.
In exchange of Odins services, PFDA
obligated itself to pay to the former 2. W/N an indirect employer is bound by the
per month for 8 hours of work daily rulings of the NLRC. YES.
the following rates: Notwithstanding that PFDA is a
Security Guard: 1990.00 government agency, its joint and
solidary liability with the
LABOR: Digests | 100215 | kb | 8
contractor (Odin) is provided for guards, in spite of Eagle Securitys
in Articles 106, 107, and 109 of mandate that ultimate liability rests
the Labor Code placing PFDAs with the principal. Employees must be
liabilities under the scope of the NLRC, guaranteed payment of wages due
in line with the definition of an them.
employer under Art. 97(b) of the III. Held
same Code. - NLRC resolution is AFFIRMED, with the
modification that BOTH PFDA and Odin are
3. Who must then carry the burden of the wage held jointly and severally liable to the security
increases? BOTH PFDA and Odin are jointly guards for the unpaid wage differentials under
and severally liable for the unpaid wage Wage Order No. 6, without prejudice to the
differentials. right of reimbursement for one-half of the
Liability under Wage Order No. 6 was amount which either the petitioner or private
sufficiently explained in Eagle Security respondent may have to pay to the security
v. NLRC, which reiterated the guards.
solidary liability of both principal
employer and job contractor for
employees money claims arising Iran v. NLRC
from provisions of a Wage Order. G.R. No. 121927; 22 April 1998; Romero, J.
According to Eagle Security, Digest prepared by Glenn Agbayani (from Paola Vargas
such solidary liability does not digest)
preclude the payors right of
reimbursement from the I. Facts
solidary co-debtor. Petitioner is engaged in softdrinks merchandising
The security guards and distribution in Mandaue City, Cebu.
contractual relationship is Private respondents were employed as
with the immediate employer drivers/salesmen and truck helpers of petitioner.
(in this case, Odin); the As part of their compensation, they received
guards immediate commissions per case of softdrinks sold.
recourse for payment of In June 1991, petitioner discovered cash shortages
wages is thus with the and irregularities allegedly committed by the
immediate employer, who private respondents. Pending investigation of their
is tasked to pay their wages. case, petitioner required them to report for work.
However, in order for the Despite the return to work order, the private
security agency to comply respondents stopped reporting for work, and their
with the new wage and act was construed as abandonment by the
allowance rates it must pay to petitioner, who terminated their services.
the security guards, the Wage Private respondents filed complaints for illegal
Order made specific dismissals, illegal deduction, underpayment of
provision to amend existing wages, premium pay for holiday and rest day,
contracts by allowing the holiday pay, service incentive leave, 13th month
adjustment of pay, allowances, separation pay, recovery cash
consideration paid by the bond, damages and attorneys fees. Said cases
principal to the security where consolidated and assigned to labor arbiter
agency. Ernesto Carreon.
In the end, ultimate liability The labor arbiter ruled that there was no illegal
for payment of the increases dismissal but petitioner failed to comply with the
rests with the principal. minimum wage requirements and the 13 th month
Additionally, the contract was entered pay.
into when Wage Order No. 6 was Both parties appealed to the NLRC. Petitioner
already in force. The wage rates in the argued that the labor arbiter erred in not including
Security Agreement were thus the commissions paid to the private respondents in
stipulated without consideration of determining their minimum wage. He likewise
the increases mandated by the Wage presented for the first time on appeal vouchers
Order. for 13th month pay signed by the private
Private respondent Odin must respondents.
therefore also be held The NLRC disregarded the vouchers presented by
equally guilty for being first Iran as proof of payment of 13th month pay
to deprive the security guards because it was only raised on appeal.
of their rightful wage under
On the issue of dismissal, the NLRC ruled that
Wage Order No. 6.
private respondents were validly dismissed but the
As employer of the security
petitioner failed to comply with the procedural
guards, the security agency is
requirements for dismissing employees for which
charged with knowledge of
they should be indemnify.
labor laws and the adequacy
On the issue of wages, the NLRC held that in
of the compensation that it
demands. computing the minimum wage, the commission
paid to the private respondents must not be
Odin cannot exculpate itself from
included because commission is an incentive for an
liability by filing the complaint in its
employee to work harder for a better production
own behalf and that of the security
LABOR: Digests | 100215 | kb | 9
that will benefit both the employer and the the ER must furnish the EE with 2 written notices
employee. To include the commission in the before the latter can be legally terminated: (a)
computation of wage in order to comply with labor notice apprising the EE of the particular acts or
standard laws is to negate the practice that a omissions for which his dismissal is sought, and (b)
commission is granted after an employee has subsequent notice informing the EE of the ERs
already earned the minimum wage or even beyond decision to dismiss him. In the instant case, per
it. admission of the petitioner, in giving the report to
work to the respondents, he was not intending to
II. Issue dismiss them but only to recover the
misappropriated funds.
WON commissions are included in determining compliance The twin requirements of notice and hearing
with the minimum wage requirement constitute the essential elements of due process,
and neither of these elements can be disregarded
III. RATIO without running afoul of the constitutional
guarantee. Not being mere technicalities but the
On 13th Month Pay very essence of due process, to which every EE is
entitled so as to ensure that the ERs prerogative
NLRC should have admitted the vouchers proving to dismiss is not exercised arbitrarily, these
payment of 13th month pay as evidence even if it requisites must be complied with strictly. For non-
was submitted only on appeal. In labor cases, compliance, private respondents were awarded
technical rules of evidence are not binding. Labor nominal damages.
officials should use all reasonable means to
ascertain facts speedily and objectively without
regard to technicalities of procedure. Millares v NLRC
The vouchers presented by Iran covers only a G.R. No. 122827, March 29, 1999, J. Bellosillo
particular year. It does not cover amounts for other Digest Prepared by Leigh
years claimed by private respondents. Only the
amounts for covered by the vouchers for that FACTS:
particular year will be credited.
Paper Industries Corporation of the Philippines
On Minimum Wage (PICOP; private respondent) suffered a financial
setback due to government regulations on logging,
The decision of the NLRC is modified insofar as it and the economic crisis
excludes the commissions received by the private o Undertook a retrenchment program.
respondents in the determination of petitioners Terminated the services of the petitioners.
compliance with the minimum wage. The case is o 116 petitioners Technical staff, unit
remanded to the labor arbiter for recomputation. manager, section manager, department
The definition of wage in Art. 97(f) of the Labor manager, division manager and vice
Code includes commissions as part of wages. president in the mill site of the respondent
Wage paid to any employee shall mean the o Petitioners were paid separation pay (1
remuneration or earnings, however designated, month basic pay for every year of service)
capable of being expressed in terms of money, Complaint filed for payment of separation pay
whether fixed or ascertained on a time, task, piece, differentials because they believed that their
or commission basis, or other method of monthly allowances should be included in the
calculating the same, xxx. computation of their separation pay
While commissions are incentives or forms of o These allowances included:
encouragement to inspire employees to put a little Staff/Managers allowance
more industry on the jobs assigned to them, still (housing allowance)
they are direct remunerations for services Transportation allowance
rendered. Commissions are the recompense, Bislig allowance
compensation or reward of an agent, salesman, Labor Arbiter applied Art 97 (f). Allowances
executor, trustee, receiver, factor, broker or bailee, should be part of the wages because they were
when the same is calculated as a percentage on customarily paid by the respondent and received
the amount of his transactions or on the profit to by the petitioners
the principal. The nature of the work of a o Santos v NLRC and Soriano v NLRC:
salesman and the reason for such type of computation of separation pay should
remuneration for services rendered shows that include the basic salary and the regular
commissions are part of a salesmans wage or allowances received by the employee
salary. o Ordered PICOP to pay separation pay
Moreover, there is no law requiring that differentials plus 10% as attorneys fees
commissions be paid only after the minimum wage NLRC set aside LA decision; allowances not part
has been paid. The establishment of a minimum of the salary base used to compute separation pay
wage only sets the floor below which an o The cases relied on by the LA involved
employees remuneration cannot fall.
illegal dismissal, where separation pay was
Were the commissions equal to or even exceed the granted in lieu of reinstatement
minimum wage, the employer need not pay, in o Estate of the late Eugene Kneebone v
addition, the basis minimum pay prescribed by law. NLRC representation and transportation
On the issue of non-compliance with the procedural allowances not part of the salary, therefore
requirements in dismissal, the Court agrees with excluded from separation pay computation
NLRC. Settled is the rule in termination of EEs that
LABOR: Digests | 100215 | kb | 10
o Allowances enjoyed by the petitioners in
were contingency based, thus not included
in the salaries
Petitioners Arguments PETITION DISMISSED .
o Allowances are included in the definition of
facilities in Art 97 (f) because they are
necessary and indispensable for their SLL International Cables v. NLRC
existence and subsistence G.R. No. 172161; 02 March 2011; Mendoza, J.
o Availment of the monetary equivalent of Digest prepared by Jeane Yaneza
those facilities was characterized by
permanency, regularity and customariness Doctrine
Supplement - The benefit or privilege given to the
ISSUES/HELD/RATIO employee which constitutes an extra remuneration above
and over his basic or ordinary earning or wage
1. W/N the allowances should be included in computation of Facility The benefit or privilege is part of the laborers'
the separation pay for retrenched personnel YES basic wages

It is the obligation of the employer to pay a I. Facts

retrenched employee the whole amount of his Lopez, Caete, and Zuiga were hired by SLL International
salaries plus all other benefits, bonuses and Cables as apprentices or trainee cable/lineman. They were
general increases to which he would have been paid full minimum wage. They did not have to report to
normally entitled had he not been retrenched. work regularly since they were only trainees. They were
substitutes to the regular workers or in undertakings that
2. W/N the allowances received by the petitioners were needed extra workers to expedite completion of work.
regularly received -- NO
After their training period, Lopez, et al were engaged as
In cases of retrenchment to prevent losses, Art 283 project employees in several projects. After the completion
of each project, their employment was terminated.
o Separation pay to be given to affected
March - December 1997 (Islacom project in Bohol)
employees, equivalent of 1 month pay or
at least month pay for every year of Received P145.00 which was the minimum
service, whichever is higher prescribed daily wage in Region VII
The term pay and wage in Art 97 refer to the July: Regional Wage Board increased the minimum
same thing reward or recompense for services prescribed daily wage to P150.00
performed Oct: Minimum prescribed daily wage increased to
Based on the definition of wages in Art 97(f), three P155.00
things must be taken note of:
March 1998 - September 1998 (PLDT Antipolo, Rizal
Term Definition project)
Customary Long established, constant Received P145.00 only
practice; regularity Prescribed minimum wage in Rizal was P160.00

November 1998 - March 1999 (Racitelcom project in

Received P145.00 only

May 1999 - Feb 2000 (Furukawa Corporation project

in Camarin, Caloocan City)
May - Dec: Received P145.00 only
Prescribed minimum wage in Manila was P198.00
Jan - Feb: Received P165.00 only
Prescribed minimum wage in Manila was P213.00
Board, lodging or other facilities articles or services
facilities for the benefit of the employee or For reasons of delay on the delivery of imported materials
his family but excluding tools of from Furukawa Corporation, the Camarin project was not
the trade or articles or service completed on the scheduled date of completion. Lagon,
primarily for the benefit of the manager of SLL International Cables was constrained to cut
employer or necessary to the down the overtime work of its workers including Lopez, et
conduct of the employers al. Thus, when Lopez, et al requested to work overtime,
business Lagon refused and told them that if they insist, they would
have to go home at their own expense and that they would
not be given anymore time nor allowed to stay in the
Fair and reasonable value quarters.
as determined by the SOLE
This prompted Lopez, et al to leave their work and return
home to Cebu. They filed a complaint for illegal dismissal,
non- payment of wages, holiday pay, 13th month pay for
1997 and 1998 and service incentive leave pay as well as
damages and attorney's fees.
LABOR: Digests | 100215 | kb | 11
An employer may provide subsidized meals and snacks to
SLLs Arguments: Lopez, et al were only project his employees provided that the subsidy shall not be less
employees. Their services were merely engaged for a that 30% of the fair and reasonable value of such facilities.
specific project or undertaking and the same were covered
by contracts duly signed by them. The food allowance of In such cases, the employer may deduct from the wages of
P63.00 per day, their allowance for lodging house, the employees not more than 70% of the value of the
transportation, electricity, water and snacks allowance meals and snacks enjoyed by the latter, provided that such
should be added to their basic pay. Thus, they received a deduction is with the written authorization of the
higher wage rate than that prescribed in Rizal and Manila. employees concerned.

LA: Lopez, et al were underpaid. The free board and Before the value of facilities can be deducted from the
lodging, electricity, water, and food enjoyed by Lopez, et al employees' wages, the following must be met:
could not be included in the computation of their wages Proof must be shown that such facilities are
because these were given without their written consent. customarily furnished by the trade
However, there was no illegal dismissal. The provision of deductible facilities must be
NLRC and CA: Affirmed LA voluntarily accepted in writing by the employee
The facilities must be charged at reasonable value
II. Issues/Held
1. Whether or not Lopez et al are entitled to minimum These requirements have not been met in this case.
wage YES
SLL failed to present any company policy or guideline
2. Whether or not the value of facilities that Lopez,
showing that provisions for meals and lodging were
et al enjoyed should be included in the
part of the employee's salaries.
computation of wages NO. The Court clarified
It also failed to provide proof of the employees' written
that the benefits they received were supplements
and not facilities. authorization or how they arrived at their valuations.
It is not even clear whether Lopez et al actually
III. Ratio enjoyed said facilities.
1. Whether or not Lopez et al are entitled to
minimum wage - YES There is also a distinction between "facilities" and
The burden of proving payment of monetary claims rests on "supplements." The food and lodging, or the electricity and
the employer, the rationale being that the pertinent water allegedly consumed by Lopez et al in this case were
personnel files, payrolls, records, remittances and other not facilities but supplements. In the case of Atok-Big
similar documents -- which will show that overtime, Wedge Assn. v. Atok-Big Wedge Co., the two terms were
differentials, service incentive leave and other claims of distinguished from one another:
workers have been paid -- are not in the possession of the
worker but in the custody and absolute control of the Supplements therefore, constitute extra remuneration or Facilities
employer. In this case, SLL, aside from bare allegations that special privileges or benefits given to or received by the laborer's
Lopez et al received wages higher than the prescribed laborers over and above their ordinary earnings or that by e
minimum, failed to present any evidence to support their wages the wag
defense of payment. deductib
the labo
Lopez, et al are entitled to be paid the minimum wage, same.
whether they are regular or non-regular employees. Section
3, Rule VII of the IRR of the Labor specifically enumerates The distinction lies not so much in the kind of benefit or
those who are not covered by the payment of minimum item (food, lodging, bonus or sick leave) given, but in the
wage. Project employees are not among them. purpose for which it is given. In the case at bar, the items
provided were given freely by SLL for the purpose of
2. Whether or not the value of facilities that maintaining the efficiency and health of its workers while
Lopez, et al enjoyed should be included in the they were working at their respective projects.
computation of wages
Section 1 of DOLE Memorandum Circular No. 2

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