Maternity Children’s Hospital vs.

Secretary of Labor

Facts

Petitioner Maternity Children’s Hospital is a semi-governmental hospital in

Cagayan De Oro which has a total of forty-one (41) employees.

Sometime in 1986, ten (10) employees of the petitioner employed in different

capacities/positions filed a complaint with the Office of the Regional Director of Labor
and Employment, Region X, for underpayment of their salaries and ECOLAs.

After investigation of two Labor Standard and Welfare Officers as directed by the
Regional Director of the records of the petitioner to verify their allegations, it ruled in
favor of the employees – directing the petitioner to pay the deficient salary entitled to the
employees.

Petitioner questions the jurisdiction of the Regional Director in resolving the case.

Issue

Does the Regional Director have the power to resolve the matter at hand - a
labor standard case?

Law Applicable/ Legal Principle

E.O. No. 111 applies as it amended the visitorial and enforcement powers of the
Regional Director which is provided by Article 128-b of the Labor Code. Said E.O. No.
111 reflects the intention enunciated in Policy Instructions Nos. 6 and 37 to empower
the Regional Directors to resolve uncontested money claims in cases where an
employer-employee relationship still exists.

The enforcement / adjudication authority of the Regional Director over

uncontested money claims in cases where an employer-employee relationship was just
confirmed and reiterated under E.O. 111.

Case History

Petitioner appealed to the Minister of Labor after the issuance of judgment of the
Regional Director but the decision was only modified as to its computation. Thereafter,
the Secretary of Labor denied his motion for reconsideration. After which, the case was
brought for resolution of the Supreme Court via a petition for certiorari.

Ruling by the SC

Yes, the Regional Director is within his powers in resolving the case. While E.O.
No. 111 was issued on December 24, 1986 or three (3) months after the promulgation
of the Secretary of Labor’s decision upholding private respondents’ salary differentials
and ECOLAs on September 24, 1986, it was ruled that the executive order should be “to
be considered in the nature of a curative statute with retrospective application.”

Opinion of the Student

I agree with the ruling of the Supreme Court since the ruling was ultimately based
on the legislative intent of the administrative policy which empowers the Regional
Director to resolve uncontested money claims where there is an employer-employee
relationship.

What E.O. 111 did is just merely reiterate what was already intended.
P.I. Manufacturing, Incorporated, vs. P.I. Manufacturing Supervisors and Foremen
Association

Facts

Petitioner P.I. Manufacturing, Incorporated is a domestic corporation engaged in

the manufacture and sale of household appliances. On the other hand, respondent P.I.
Manufacturing Supervisors and Foremen Association (PIMASUFA) is an organization of
petitioner’s supervisors and foremen.

R.A.No. 6640 was passed which increased the statutory minimum wage and
salary rates of employees and workers in the private sector. Later on, petitioner and
respondent entered into a new collective bargaining agreement whereby supervisors
and foremen were granted an increase and made retroactive.

Respondent then sued petitioner for not complying with R.A.No. 6640.

Issues

Did the petitioner violate R.A. No. 6640 thus entitling the members of the
respondent to increase in salary in consideration of the executed Collective Bargaining
Agreement?

Law Applicable/ Legal Principle

In this case, while the protection for labor force of the Constitution was
considered, the Supreme Court also considered the interest of the petitioner was
applied because while the Constitution mandates the protection of the workforce,
consideration must also be made to the employer which may unjustly suffer with the
demand of the employees.

Case History

The respondent in filing the case was favored by the Labor arbiter as well as the
National Labor Relations Commission which brought the case to the Supreme Court by
the petitioner but it was first remanded to Court of Appeals, however, it also ruled
against the petitioner. Thereafter the Supreme Court also ruled against the petitioner,
hence this motion for reconsideration.

Ruling by the SC

No, petitioner did not violate said law. The law only provided increase for
selected employees and not all employees as specified. The Supreme Court ruled that,
to direct petitioner to grant an across-the-board increase to all of them, regardless of the
amount of wages they are already receiving, would be harsh and unfair to the former.

Moreover, included in the CBA is the respondents’ concession to the benefits of

the law enacted. It was ruled that respondents cannot invoke the beneficial provisions of
the 1987 CBA but disregard the concessions it voluntary extended to petitioner. The
goal of collective bargaining is the making of agreements that will stabilize business
conditions and fix fair standards of working conditions.

Opinion of the Student

I am in favor of the ruling of the Supreme Court as it upholds fair and objective
decision-making.

I believe that while as a general rule, labor force must be given protection, in this
case, considering the employer’s situation should be made because they would be
unjustly burdened by granting across-the-board benefits demanded by the employees
which would ultimately have a negative impact on the employees since they will also be
affected if the company would be financially prejudiced.
Boy Scouts of the Philippines vs. Juliana V. Araos

Facts

The petitioner, Boy Scouts of the Philippines (“BSP”) is a public corporation

created under Commonwealth Act 111. Unlike other corporations, BSP is not organized
or operated for profit or engaged in industry.

Respondent Juliana V. Araos worked with the petitioner as scout executive.

During her incumbency, she organized the BSP Employees Welfare Association, a sort
of labor organization or union of employees working in the Boy Scouts of the Philippines
to which she became president thereof.

Respondent filed charges against Chief Scout Executive, for alleged "anomalous
actuations” to the NBI and eventually was found guilty. Later on, respondent received a
letter dismissing her from her position because of what she did as it was prejudicial to
the BSP. Respondent filed charges against BSP for unfair labor practice but petitioner
contends that the Court of Industrial Relations (“CIR”) does not have a jurisdiction over
the case.

Issues

Does the Court of Industrial Relations have jurisdiction over the case?

Law Applicable/ Legal Principle

The Industrial Peace Act applies as it defines what is included in the words
“employer” and “employee” which would then dictate the jurisdiction of the CIR.

Case History

The CIR ruled in favor of respondent and the motion for reconsideration of the
petitioner was also denied, hence this petition for review by certiorari.

Ruling by the SC

No. It does not apply to the BSP as it is a corporation engaged in civic and
benevolent activities.

It is not included in the definition of "employer" contained in Republic Act 875 or

the Industrial Peace Act, and its employees do not fall under the definition of
"employee" contained in the said Act, which is concerned with regulating relations
between management and labor, and which refers only to organizations and entities
created and operated for profit or engaged in a profitable trade, occupation or industry.

As a result thereof, Republic Act 875, particularly that portion regarding labor
disputes and unfair labor practice, does not apply to the Boy Scouts of the Philippines.

Opinion of the Student

I am not in favor of the decision of the Supreme Court in this case. I believe that
an employee, whether employed in a corporation for profit or not, as in this case, the
rights of the employees against unfair labor practice do not change.

In this case, the issue was the act of BSP in dismissing the respondent outright
even though she had basis in her actuations and the NBI actually resolved in favor of
her in the issue of the other employee of the corporation.

In resolving the jurisdiction of the CIR, I believe there should be no difference

between a corporation organized for profit and those for lofty objectives.
National Federation of Sugar Workers (NFSW), vs. Ethelwoldo R. Ovejera, Central
Azucarera De La Carlota

Facts

NFSW has been the bargaining agent of CAC rank and file employees and has
concluded with CAC a collective bargaining agreement which includes payment of
Christmas and Milling bonuses.

Later on, NFSW demanded for addition of 13th month pay in accordance with PD
851 but the parties agreed that the basis of their claim would be the pending case
before the Supreme Court which would resolve whether an employer should be held
liable for 13th month pay on top of the other bonuses given. However, the Supreme
Court dismissed the case.

NSFW again demanded for the 13th month pay which was denied by the CAC.

Issues

Are the employees entitled to demand a 13th month pay in addition to the other
bonuses being given to them by CAC?

Law Applicable/ Legal Principle

PD 851 is applicable as its interpretation would determine whether the

employees who are already receiving certain bonuses may still demand a 13 th month
pay.

Case History

NSFW filed with the Ministry of Labor and Employment Regional Office a notice
to strike based on non-payment of the 13th month pay. Six days after, they stuck and
CAC filed a petition to declare the strike illegal.

After the labor arbiter declared the NFSW strike illegal, NSFW filed this petition
for prohibition seeking to annul the decision of the labor arbiter bypassing the NLRC.

Ruling by the SC

No, the employees in this case are not entitled to a 13th month pay.

Upon examination of the provisions of PD 851, it was ruled by the Supreme

Court that the evident intention of the law was only to grant an additional income in the
form of a 13th month pay to employees not already receiving the same.

In this case, it was observed that the employees claiming such benefit are
already receiving other forms of bonuses so that if it were to be granted that they are
entitled to a 13th month pay, it would in effect be a 14th or 15th month pay. This view was
grounded on the fact that there is a provided exemption in the law which does not
distinguish in exempting from application those who are already receiving a 13 th month
pay or its equivalent. To grant this petition would serve contrary to the intention of the
law.

Opinion of the Student

I am in favor of the decision of the Supreme Court as there was no injustice done
to the employees. Here, if the 13th month pay is to be granted in addition to the other
bonuses the employees have been receiving before the passage of the law, the
respondent would be unjustly prejudiced thereby. The employees here were not
deprived of benefits since they were already receiving before the passage of PD 851.
Marcopper Mining Corporation vs National Labor Relations Commission

Facts

Marcopper Mining Corporation engaged in the business of mineral prospecting,

exploration and extraction. On the other hand, private respondent NA-MAWU-MIF is a
labor federation duly organized and registered with the Department of Labor and
Employment (DOLE), to which the Marcopper Employees Union (the exclusive
bargaining agent of all rank-and file workers of petitioner) is affiliated, entered into a
Collective Bargaining Agreement (CBA) granting employees of 10% wage increase.

However, EO 178 was enacted mandating the integration of the cost of living
allowance into the basic wage of workers with retroactive effect. Consequently, the
basic wage rate of petitioner’s laborers categorized as non-agricultural workers was
increased by P9.00 per day. When petitioner implemented the second five percent (5%)
wage increase and thereafter added the integrated COLA, private respondent assailed
the manner in which the second wage increase was effected. It argued that the COLA
should first be integrated into the basic wage before the 5% wage increase is computed.

Issues

Did the petitioner commit underpayment to its employees?

Law Applicable/ Legal Principle

EO 178 applies since interpreting it would shed light to the confusion of

underpayment by the petitioner.

Case History

The union filed a complaint for underpayment of wages before the Regional
Arbitration Branch IV of Quezon City. When the labor arbiter ruled in favor of the union,
petitioner appealed to the NLRC but it sustained the ruling of the Labor Arbiter, hence
this petition for certiorari and prohibition under Rule 65 of the Revised Rules of Court.

Ruling by the SC

Yes, the petitioner committed underpayment to its employees. Upon examination

of the law as well as the CBA of the parties, the Court ruled that while CBA is the law
between the contracting parties, the case at bar also requires conferring with the law
applicable. Here, as the law had retroactive effect, it is not contrary to the CBA if the
COLA would be integrated with the basic pay.

It was further rules that the law here is mandatory and beyond contractual
stipulations between the parties, therefore, whether or not petitioner intended the basic
wage to include the COLA becomes immaterial.

Opinion of the Student

I am in favor of the decision of the Supreme Court since the decision is in

keeping with what is enshrined in the Constitution - to accord utmost protection and
justice to labor.

Here, due consideration was made to the petitioner as the CBA was considered
in resolving the case. But it is not in the hands of the Court that a mandatory law was
enacted in timing with the CBA of the parties with retroactive effect thereby affecting the
computation previously agreed upon. Since a mandatory law was enacted, the Court
has no choice but to uphold it, because doing otherwise would unjustly prejudice the
employees.