i.

Student Name:
ii. Complete Case Title Citation: 20. ​Union of Filipro Employees v. Vivar, Jr., 205 SCRA 200
iii. Statement of the issue/s: ​Whether or not the employees must return the alleged excessive
salary in light of the principle of solutio indebiti since the divisor in computing for the daily rate,
according to the employer, must be 261 and not 251 since the 10 days of holiday was paid.

iv. Complainant’s argument/s:

“The respondent arbitrator's order to change the divisor from 251 to 261 days would result in a
lower daily rate which is violative of the prohibition on non-diminution of benefits found in
Article 100 of the Labor Code.”

v. Respondent’s argument/s: ​Employees must return the excessive salary by virtue of ​solutio
indebiti​, or payment by mistake, due to its use of 251 days

vi. Instruction Learned: ​According to Article 4 of the Labor Code, all doubts in the
implementation and interpretation of this Code, including its implementing rules and regulations,
shall be resolved in favor of labor

Vii. Decision of the Court: ​No, employees should not return the alleged excessive salary.

Viii. Ratio: ​“Respondent Nestle's invocation of ​solutio indebiti​, or payment by mistake, due to
its use of 251 days as divisor must fail in light of the Labor Code mandate that "all doubts in the
implementation and interpretation of this Code, including its implementing rules and regulations,
shall be resolved in favor of labor." (Article 4). Moreover, prior to September 1, 1980, when the
company was on a 6-day working schedule, the divisor used by the company was 303, indicating
that the 10 holidays were likewise not paid. When Filipro shifted to a 5-day working schedule on
September 1, 1980, it had the chance to rectify its error, if ever there was one but did not do so. It
is now too late to allege payment by mistake.”
i. Student Name:
ii. Complete Case Title Citation: 21. FEM’s Elegance Lodging House, Inc. v. Hon. Murillo,
G.R. No. 117442-43, 11 January 1995
iii. Statement of the issue/s:
Whether the Labor Arbiter acted with grave abuse of discretion when it allowed the
belated filing of respondent's position paper and denied the petitioner’s motion to dismiss which,
in turn, resulted in the denial of the latter’s right to due process of the law.

iv. Complainant’s argument/s:

FEM claimed that the Labor Arbiter should have cited respondents in contempt.

v. Respondent’s argument/s:
The Labor Arbiter held that a fifteen-day delay in filing the position paper was not
unreasonable considering that the substantive rights of litigants should not be sacrificed by a
technicality; that all doubts in the interpretation of the Labor Code should be construed in favor
of labor.

vi. Instruction Learned:

Respondent’s failure to submit their position papers were only technical defects that are
not a ground for dismissal. Substantive rights of litigants should not be sacrificed by mere
technicality. When there’s doubt in the interpretation of a provision of the law, it should be
resolved in favor of labor. It is the State’s policy to afford full protection to labor whenever
conflict arises between them and management.

Decision of the Court:

● The LA did not commit grave abuse of discretion; technicality should not outweigh
substantial rights; FEM’s was not denied due process of law.

vii. Ratio:
● Petitioner failed to exhaust all other remedies. Particularly, in seeking redress from the
NLRC.
● The delay of private respondents in the submission of their position paper is a procedural
flaw, and the admission thereof is within the discretion of the Labor Arbiter. Well-settled
is the rule that technical rules of procedure are not binding in labor cases, for procedural
lapses may be disregarded in the interest of substantial justice, particularly where labor
matters are concerned.
● Article 4 of the Labor Code of the Philippines resolves that all doubts in the interpretation
of the law and its implementing rules and regulations shall be construed in favor of labor.
Where conflicting interests between labor and management exist, the State's basic policy
of extending protection to Labor.
● The fact that the LA reviewed their position papers and FEM’s motion for
reconsideration belies the allegation of denial of due process of law.
i. Student Name:
ii. Complete Case Title Citation: 22. Villa Vert v. ECC and GSIS, G.R. No. L-48605
December 14, 1981
iii. Statement of the issue/s:
Whether the petitioner can claim death benefits from the respondent following the death
of her son which is allegedly related to his work as a code verifier with the Philippine
Constabulary.
iv. Complainant’s argument/s:

v. Respondent’s argument/s:
ECC and GSIS argue that the petitioner failed to establish the causal connection between
the petitioner’s death and his job which merely involves typing of confidential information and
preparing all sorts of paper works.

vi. Instruction Learned:

When there is doubt in the interpretation and implementation of the Labor Code,
including its IRR, it should be resolved in favor of labor. The presumption was that the employee
was healthy when he started working with the Philippine Constabulary. Aside from the obvious
suspects, which are lacking in this case, it can only be justly inferred that the nature of his work
caused the acute hemorrhagic pancreatitis.

Decision of the Court:

● Petition was granted. GSIS was ordered to pay death benefits.

vii. Ratio:
● Marcelino’s cause of death was found to be directly caused or at least aggravated by the
duties he performed as code verifier, computer operator, and clerk typist of the Philippine
Constabulary.
● There was no sign that the pancreatitis was caused by recent massive alcohol
intoxication.
● Per the medico-legal officer, the exact cause of acute hemorrhagic pancreatitis is still
unknown despite extensive research in this field, although most research data are agreed
that physical and mental stresses are strong causal factors in the development of the
disease.