Mindanao State University

MSU College of Law

Iligan Extension

CASE DIGESTS
and
CASE DOCTRINES

In Compliance for the Course Subject on

Labor Law Review

Submitted by:
GROUP 8

Carlo Apas
Aljade Laut
Aldrin Loyola
Ibrahim Lyndon Razuman
Nujoma Salbo

Fifth Year
Submitted to:
Labor Arbiter Abdul Azis U. Metmug
September 14, 2019
CASE 21 DIGEST & DOCTRINES

G.R. No. 188169 November 28, 2011

NIÑA JEWELRY MANUFACTURING OF METAL ARTS,

INC. (otherwise known as NIÑA MANUFACTURING
AND METAL ARTS, INC.) and ELISEA B. ABELLA,
Petitioners,
vs.
MADELINE C. MONTECILLO and LIZA M. TRINIDAD,
Respondents.

FACTS:
Madeline Montecillo and Liza Trinidad (Respondents) were employees of Niña
Jewelry Manufacturing of Metal Arts (Petitioner). Petitioner required their
employees to pay cash bond or deposits in varying amounts but not to exceed 15%
of their salary per week, or in the alternative, sign authorization allowing petitioner
to deduct their salaries not exceeding 15% of their take home pay if it was found
that they lost the gold entrusted to them. Such policy was due to the incidents of
theft.

Respondents alleged that Petitioner left them no option but to post bail to continue
working and claimed that they were constructively dismissed because of such
policy.

Petitioner alleged otherwise, claiming that the respondents no longer reported for
work in an act of defiance of the policy imposed. Labor Arbiter decided in favor of
Petitioner finding that there was no constructive dismissal since it was indeed the
respondents who did not report to work to defy the policy imposed by the
employer. NLRC affirmed the petition, but CA later reversed it. Hence, this petition.

ISSUES:
1. Whether or not deductions imposed by the employer is valid.
2. Whether or not there was constructive dismissal.

RULING:
1. No, the deductions were invalid. The SC held that the general rule is there
must be no deductions to be made except upon the instances provided in
Article 113 and 114 of the Labor Code. Article 113 and 114 are both clear
upon the exceptions. SC added that the deduction may fall upon the ambit of
par.2 of Article 114, however no such rules or regulations are provided on
making deposits in a jewelry-making enterprise, the petitioner should have
 sought such regulation from the Secretary of Labor before implementing
such rule lest it be declared illegal.

2. No, the SC upheld that the decisions and findings of the LA and NLRC are
given more weight and substance since the decision is supported by
competent evidence and the reversal of the CA is improper.

CASE DOCTRINES

1. It is settled that SC is bound by the Court of Appeal’s factual findings. Rule

admits of exceptions.

“It is thus settled that the SC is bound by the CA’s factual findings. The rule, however,
admits of exceptions, among which is when the CA’s findings are contrary to those of
the trial court or administrative body exercising quasi-judicial functions from which
the action originated.”1

2. In certiorari proceedings under Rule 65 of the Rules of Court, the appellate

court does not assess and weigh the sufficiency of evidence upon which the
Labor Arbiter and the National Labor Relations Commission (NLRC) based
their conclusion.

“x x x [I]n certiorari proceedings under Rule 65 of the Rules of Court, the appellate
court does not assess and weigh the sufficiency of evidence upon which the Labor
Arbiter and the NLRC based their conclusion. The query in this proceeding is limited
to the determination of whether or not the NLRC acted without or in excess of its
jurisdiction or with grave abuse of discretion in rendering its decision. However, as
an exception, the appellate court may examine and measure the factual findings of
the NLRC if the same are not supported by substantial evidence. x x x.”2

3. Guidelines relative to the conduct of judicial review of decisions rendered by

administrative agencies in the exercise of their quasi-judicial power.

“The SC defined substantial evidence and laid down guidelines relative to the
conduct of judicial review of decisions rendered by administrative agencies in the
exercise of their quasi-judicial power, viz.: x x x Substantial evidence is more than a
mere scintilla of evidence. It means such relevant evidence as a reasonable mind
might accept as adequate to support a conclusion, even if other minds equally
reasonable might conceivably opine otherwise.

1
AMA Computer College-East Rizal, et al. v. Allan Raymond Ignacio, G.R. No. 178520, June 23, 2009, 590
SCRA 633, 651.
2
Protacio v. Laya Mananghaya & Co., G.R. No. 168654, March 25, 2009, 582 SCRA 417, 427.
Second, in reviewing administrative decisions of the executive branch of the
government, the findings of facts made therein are to be respected so long as they
are supported by substantial evidence. Hence, it is not for the reviewing court to
weigh the conflicting evidence, determine the credibility of witnesses, or otherwise
substitute its judgment for that of the administrative agency with respect to the
sufficiency of evidence.

Third, administrative decisions in matters within the executive jurisdiction can only
be set aside on proof of gross abuse of discretion, fraud, or error of law. These
principles negate the power of the reviewing court to re-examine the sufficiency of
the evidence in an administrative case as if originally instituted therein, and do not
authorize the court to receive additional evidence that was not submitted to the
administrative agency concerned.”3

4. When constructive dismissal occurs.

“Constructive dismissal occurs when there is cessation of work because continued

employment is rendered impossible, unreasonable or unlikely; when there is a
demotion in rank or diminution in pay or both; or when a clear discrimination,
insensibility, or disdain by an employer becomes unbearable to the employee.”4

5. Article 113 of the Labor Code is clear that there are only three exceptions to
the general rule that no deductions from the employees’ salaries can be
made.

“Article 113 of the Labor Code is clear that there are only three exceptions to the
general rule that no deductions from the employees’ salaries can be made. The
exception which finds application in the instant petition is in cases where the
employer is authorized by law or regulations issued by the Secretary of Labor to
effect the deductions. On the other hand, Article 114 states that generally, deposits
for loss or damages are not allowed except in cases where the employer is engaged
in such trades, occupations or business where the practice of making deposits is a
recognized one, or is necessary or desirable as determined by the Secretary of Labor
in appropriate rules or regulations.”5

3
G.R. No. 175201, April 23, 2008, 552 SCRA 589, citing Montemayor v. Bundalian, 453 Phil 158, 167
(2003).
4
Fe La Rosa, et al. v. Ambassador Hotel, G.R. No. 177059, March 13, 2009, 581 SCRA 340, 346-347.
5
Article 113-114, Labor Code of the Philippines
CASE 22 DIGEST & DOCTRINES

G.R. No. 168654 March 25, 2009

ZAYBER JOHN B. PROTACIO, Petitioner,

vs.
LAYA MANANGHAYA & CO. and/or MARIO
MANANGHAYA, Respondents.

FACTS:
Respondent KPMG Laya Mananghaya & Co. (respondent firm) hired petitioner
Zayber John B. Protacio as Tax Manager on 01 April 1996. On 30 August 1999,
petitioner tendered his resignation effective 30 September 1999. [Employed 3
years, 4 months]

On 01 December 1999, petitioner demanded a claim for payment of the cash

commutation of his leave credits, and lump sum pay. Respondent failed to pay. Thus,
petitioner filed before the NLRC a complaint for the non-payment of the cash
equivalent of petitioner’s leave credits in the amount, and lump sum pay for the
fiscal year 1999.

During the pendency of the case before the Labor Arbiter, respondent paid
petitioner’s claims except the lump sum pay. Petitioner acknowledged the receipt of
the payment but disputed the computation of the cash value of his vacation leave
credits, and demanded the lump sum pay.

The Labor Arbiter rendered a decision ordering respondent to pay the following:
(1) ₱28,407.08 - representing the underpayment of the cash equivalent of the
unused leave credits;
(2) ₱573,000.00 - representing complainant’s 1999 year-end lump sum payment.

Respondent appealed to the NLRC, where the NLRC affirmed the findings of the LA.

Respondents filed a motion for reconsideration but the NLRC denied the motion for
lack of merit. Hence, respondents elevated the matter to the Court of Appeals via
petition for certiorari. [Rule 65]

Court of Appeals reversed the findings of the NLRC and the LA with respect to the
award of the year-end lump sum pay and the cash value of petitioner’s leave credits.

Petitioner sought reconsideration. CA denied petitioner’s motion for

reconsideration for lack of merit.
Petitioner filed a Review for Certiorari with the Supreme Court, assailing the CA’s
decision.

ISSUES:
1. Whether CA is correct in taking cognizance of respondent’s petition for
certiorari when the resolution thereof hinges on mere evaluation of evidence.
2. Whether CA is correct in employing a larger divisor to compute petitioner’s
daily salary rate thereby diminishing his benefits.
3. Whether CA is correct in reversing the findings of both LA and NLRC on the
compensable nature of petitioner’s year end lump sum pay.

RULING:
1. Yes, the CA is correct. As a general rule, in certiorari proceedings under Rule
65 of the Rules of Court, the appellate court (CA) does not assess and weigh
the sufficiency of evidence upon which the Labor Arbiter and the NLRC based
their conclusion. The query in this proceeding is limited to the determination
of whether or not the NLRC acted without or in excess of its jurisdiction or
with grave abuse of discretion in rendering its decision. However, as an
exception, the appellate court (CA) may examine and measure the factual
findings of the NLRC if the same are not supported by substantial evidence.
The SC has not hesitated to affirm the appellate court’s (CA) reversals of the
decisions of labor tribunals if they are not supported by substantial evidence.

2. No, the CA is not correct. With regard to the computation of the cash
equivalent of petitioner’s leave credits, the CA used a base figure of
₱71,250.00 representing petitioner’s monthly salary as opposed to
₱95,000.00 used by the LA and later affirmed by the NLRC.
Because of a lower base figure (representing the monthly salary) used by the
appellate court, the cash equivalent of petitioner’s leave credits was lowered
from ₱28,407.08 (LA’s finding) to ₱9,802.83 (CA’s finding)

The monthly compensation of ₱71,250.00 used as base figure by the CA is

totally without basis. As correctly held by the LA and the NLRC, the evidence
on record reveals that petitioner was receiving a monthly compensation of
₱95,000.00 consisting of a basic salary of ₱61,000.00, advance incentive pay
of ₱15,000.00, transportation allowance of ₱15,000.00 and representation
allowance of ₱4,000.00. These amounts totaling ₱95,000.00 are all deemed
part of petitioner’s monthly compensation package and, therefore, should be
the basis in the cash commutation of the petitioner’s leave credits.

The CA, LA, and NLRC used a 30-working day divisor instead of 26 days
which petitioner insists. There was an express admission on respondents’
part that they used a 26-day divisor in the cash commutation of leave credits.
Thus, with a monthly compensation of ₱95,000.00 and using a 26-working
day divisor, petitioner’s daily rate is ₱3,653.85. Based on this rate,
 petitioner’s cash equivalent of his leave credits of 23.5 is ₱85,865.48 (23.5 x
3653.85). Since petitioner has already received the amount ₱46,009.67, a
balance of ₱39,855.80 remains payable to petitioner.

3. Yes, the CA was correct. The CA held that while the lump sum payment was in
the nature of a proportionate share in the firm’s annual income to which
petitioner was entitled, the payment thereof was contingent upon the
financial position of the firm. According to the CA, since no evidence was
adduced showing the net income of the firm for fiscal year ending 1999 (date
when petitioner resigned) as well as petitioner’s corresponding share
therein, the amount awarded by the labor tribunals was a baseless
speculation and as such must be deleted.

The CA held that the amount of the year-end lump sum compensation was
not fully justified and supported by the evidence on record. The SC fully
agrees that the lump sum award of ₱573,000.00 to petitioner seemed to have
been plucked out of thin air. The appellate court (CA) was correct in holding
that the award was a mere speculation devoid of any factual basis. In the
exceptional circumstance as in the instant case, the SC finds no error in the
appellate court’s (CA) review of the evidence on record.

Petitioner Responden LA NLRC CA SC

t
Cash P55,467.6 P54,824.18 P28,407.08 Affirme P9,802.83 P39,855.8
Equivalen (of w/c (P95K/30day d LA (P71,250/30 (95K/26
t of Leave P46,009.67 s x 23.5- day- days x
Credits cash equiv. 46,009.67) divisorx23.5 23.5 =
of leave -46,009.67) 85,865.48-
cred) 46,009.67
)

Year-end P674,756. X P573,000 Affirme X Affirmed

Lump Sum 7 d LA CA

CASE DOCTRINES

1. As a general rule, in certiorari proceedings under Rule 65 of the Rules of

Court, the appellate court does not assess and weigh the sufficiency of
evidence upon which the Labor Arbiter and the NLRC based their conclusion.

“The query in this proceeding is limited to the determination of whether or not the
NLRC acted without or in excess of its jurisdiction or with grave abuse of discretion
in rendering its decision. However, as an exception, the appellate court may examine
and measure the factual findings of the NLRC if the same are not supported by
substantial evidence.”6

“The SC has not hesitated to affirm the appellate court’s reversals of the decisions of
labor tribunals if they are not supported by substantial evidence”7

2. Management prerogative on the payment of lump sum

“The distribution being merely discretionary, the year-end lump sum payment may
properly be considered as a year-end bonus or incentive. Contrary to petitioner’s claim,
the granting of the year-end lump sum amount was precisely dependent on the firm’s net
income; hence, the same was payable only after the firm’s annual net income and cash
position were determined. By definition, a "bonus" is a gratuity or act of liberality of the
giver. It is something given in addition to what is ordinarily received by or strictly due
the recipient.”8

3. Nature of bonus

“A bonus is granted and paid to an employee for his industry and loyalty which
contributed to the success of the employer’s business and made possible the
realization of profits” 9

“Generally, a bonus is not a demandable and enforceable obligation. It is so only

when it is made part of the wage or salary or compensation. When considered as
part of the compensation and therefore demandable and enforceable, the amount is
usually fixed. If the amount would be a contingent one dependent upon the
realization of the profits, the bonus is also not demandable and enforceable”10

“The SC held that if the bonus is paid only if profits are realized or a certain amount
of productivity achieved, it cannot be considered part of wages. If the desired goal of
production is not obtained, of the amount of actual work accomplished, the bonus
does not accrue. Only when the employer promises and agrees to give without any
conditions imposed for its payment, such as success of business or greater
production or output, does the bonus become part of the wage.” 11

6
Soriano, Jr. v. National Labor Relations Commission, G.R. No. 165594, 23 April 2007, citing Danzas
Intercontinental, Inc. v. Daguman, 456 SCRA 382.
7
Philippine Pizza, Inc., v. Bungabong, G.R. No. 154315, 09 May 2005, 458 SCRA 288; Danzas
Intercontinental, Inc. v. Daguman, G.R. No. 154368, 15 April 2005, 456 SCRA 382; Go v. Court of Appeals,
G.R. No. 158922, 28 May 2004, 430 SCRA 358.
8
The Manila Banking Corp. v. NLRC, 345 Phil. 105, 125 (1997).
9
Id
10
Id
11
311 Phil. 407 (1995).
 4. 30-day divisor vs 26-day divisor

“The Court of Appeals relied on Section 2, Rule IV, Book III of the implementing rules
of the Labor Code in using the 30-working day divisor. The provision essentially states
that monthly-paid employees are presumed to be paid for all days in the month whether
worked or not. The provision has long been nullified where the SC ruled that the
provision amended the Labor Code’s provisions on holiday pay by enlarging the scope of
their exclusion. Petitioner’s claim that respondent firm used a 26-working day divisor is
supported by the evidence on record. In a letter addressed to petitioner, respondents’
counsel expressly admitted that respondent used a 26-working day divisor.”12

12
217 Phil. 629 (1984).
CASE 23 DIGEST & DOCTRINES

G.R. No. 151966 July 8, 2005

JPL MARKETING PROMOTIONS, Petitioner,

vs.
COURT OF APPEALS, NATIONAL LABOR RELATIONS
COMMISSION, NOEL GONZALES, RAMON ABESA III
and FAUSTINO ANINIPOT, Respondents.

FACTS:
JPL Marketing and Promotions is a domestic corporation engaged in the business of
recruitment and placement of workers. On the other hand, private respondents Noel
Gonzales, Ramon Abesa III and Faustino Aninipot were employed by JPL as
merchandisers on separate dates and assigned at different establishments in Naga
City and Daet, Camarines Norte as attendants to the display of California Marketing
Corporation (CMC), one of petitioner’s clients.

On 13 August 1996, JPL notified private respondents that CMC would stop its direct
merchandising activity in the Bicol Region, Isabela, and Cagayan Valley effective 15
August 1996. They were advised to wait for further notice as they would be
transferred to other clients. However, on 17 October 1996, private respondents
Abesa and Gonzales filed before the NLRC Regional Arbitration Branch Sub V
complaints for illegal dismissal, praying for separation pay, 13th month pay, service
incentive leave pay and payment for moral damages.

Aninipot filed a similar case thereafter. After the submission of pertinent pleadings
by all of the parties and after some clarificatory hearings, the complaints were
consolidated and submitted for resolution. Executive Labor Arbiter dismissed the
complaints for lack of merit. The Labor Arbiter found that Gonzales and Abesa
applied with and were employed by the store where they were originally assigned
by JPL even before the lapse of the six (6)-month period given by law to JPL to
provide private respondents a new assignment. Thus, they may be considered to
have unilaterally severed their relation with JPL, and cannot charge JPL with illegal
dismissal.

The Labor Arbiter held that it was incumbent upon private respondents to wait until
they were reassigned by JPL, and if after six months they were not reassigned, they
can file an action for separation pay but not for illegal dismissal. The claims for 13th
month pay and service incentive leave pay was also denied since private
respondents were paid way above the applicable minimum wage during their
employment.

ISSUES:
1. Whether or not the respondents are entitled to separation pay.
2. Whether or not the respondents are entitled to 13th month pay and service
incentive leave pay.

RULING:
1. No. The common denominator of the instances where payment of separation
pay is warranted is that the employee was dismissed by the employer. In the
instant case, there was no dismissal to speak of. Private respondents were
simply not dismissed at all, whether legally or illegally. What they received
from JPL was not a notice of termination of employment, but a memo
informing them of the termination of CMC’s contract with JPL. More
importantly, they were advised that they were to be reassigned. At that time,
there was no severance of employment to speak of.

2. Yes. The Court has held in several instances that “service incentive leave is
clearly demandable after one year of service.” While computation for the
13th month pay should properly begin from the first day of employment, the
service incentive leave pay should start a year after commencement of
service, for it is only then that the employee is entitled to said benefit. On the
other hand, the computation for both benefits should only be up to 15 August
1996, or the last day that private respondents worked for JPL. To extend the
period to the date of finality of the NLRC resolution would negate the
absence of illegal dismissal, or to be more precise, the want of dismissal in
this case. Besides, it would be unfair to require JPL to pay private
respondents the said benefits beyond 15 August 1996 when they did not
render any service to JPL beyond that date. These benefits are given by law
on the basis of the service actually rendered by the employee, and in the
particular case of the service incentive leave, is granted as a motivation for
the employee to stay longer with the employer. There is no cause for
granting said incentive to one who has already terminated his relationship
with the employer.

CASE DOCTRINES

1. Separation pay is authorized only in cases of dismissals due to any of these

reasons.

“Under Arts. 283 and 284 of the Labor Code, separation pay is authorized only in
cases of dismissals due to any of these reasons: (a) installation of labor saving
devices; (b) redundancy; (c) retrenchment; (d) cessation of the employer’s business;
and (e) when the employee is suffering from a disease and his continued
employment is prohibited by law or is prejudicial to his health and to the health of
his co-employees.”13

2. When separation pay may also be allowed.

“However, separation pay shall be allowed as a measure of social justice in those

cases where the employee is validly dismissed for causes other than serious
misconduct or those reflecting on his moral character, but only when he was
illegally dismissed. “14

“The Labor Code provides for the payment of separation pay to an employee
entitled to reinstatement but the establishment where he is to be reinstated has
closed or has ceased operations or his present position no longer exists at the time
of reinstatement for reasons not attributable to the employer.”15

3. Separation Pay

“The common denominator of the instances where payment of separation pay is

warranted is that the employee was dismissed by the employer.”16
4. When the “floating status” of an employee lasts for more than six months.

“Art. 286 of the Labor Code allows the bona fide suspension of the operation of a
business or undertaking for a period not exceeding six (6) months, wherein an
employee/employees are placed on the so-called “floating status.” When that
“floating status” of an employee lasts for more than six months, he may be
considered to have been illegally dismissed from the service. Thus, he is entitled to
the corresponding benefits for his separation, and this would apply to suspension
either of the entire business or of a specific component thereof.”17

5. The principle of awarding separation pay on the ground of compassionate

justice, or on grounds of equity and social consideration

“The Court of Appeals relied on the cases wherein the Court awarded separation pay
to legally dismissed employees on the grounds of equity and social consideration.
Said cases involved employees who were actually dismissed by their employers,
whether for cause or not. Clearly, the principle applies only when the employee is
dismissed by the employer.”18

13
Article 283-284, Labor Code of the Philippines
14
Capili v. National Labor Relations Commission, 337 Phil. 210, 215 (1997).
15
Sec. 4 (b), Rule I, Book VI of the Implementing Rules and Regulations of the Labor Code.
16
Capili v. National Labor Relations Commission, 337 Phil. 210, 215 (1997).
17
Reynaldo Valdez v. National Labor Relations Commission, 349 Phil. 760, 766 (1998), citing Agro
Commercial Security Services Agency, Inc. v. National Labor Relations Commission, 175 SCRA 790 (1989).
18
Philippine National Construction Corporation v. National Labor Relations Commission, 366 Phil. 678
(1999); United South Dockhandlers, Inc. v. National Labor Relations Commission, et al., 267 SCRA 401
 6. The 13th month pay and service incentive leave pay are benefits mandated
by law and should be given to employees as a matter of right.

“Presidential Decree No. 851, as amended, requires an employer to pay its rank and
file employees a 13th month pay not later than 24 December of every year.
However, employers not paying their employees a 13th month pay or its equivalent
are not covered by said law.”19

“The term “its equivalent” was defined by the law’s implementing guidelines as
including Christmas bonus, mid-year bonus, cash bonuses and other payment
amounting to not less than 1/12 of the basic salary but shall not include cash and
stock dividends, cost-of-living-allowances and all other allowances regularly
enjoyed by the employee, as well as non-monetary benefits.”20

7. Service incentive leave is a yearly leave benefit of five (5) days with pay,
enjoyed by an employee who has rendered at least one year of service—it is
clearly demandable after one year of service.

“Service incentive leave, as provided in Art. 95 of the Labor Code, is a yearly leave
benefit of five (5) days with pay, enjoyed by an employee who has rendered at least
one year of service. Unless specifically excepted, all establishments are required to
grant service incentive leave to their employees. The term “at least one year of
service” shall mean service within twelve (12) months, whether continuous or
broken reckoned from the date the employee started working.”21

“The Court has held in several instances that “service incentive leave is clearly
demandable after one year of service.”22

8. Difference between minimum wage and actual salary cannot be deemed as

13th month pay and service incentive leave pay.

“The difference between the minimum wage and the actual salary received by the
employees cannot be deemed as their 13th month pay and service incentive leave
pay as such difference is not equivalent to or of the same import as the said benefits
contemplated by law.”23

(1997); Firestone Tire and Rubber Co. of the Philippines v. Lariosa, et al., 148 SCRA 186 (1987); Rollo, pp.
32-33.
19
Sec. 2, P.D. No. 851.
20
Section 3(e), Rules and Regulations Implementing P.D. No. 851.
21
Sec. 3, Rule V, Book III, Rules to Implement the Labor Code.
22
Imbuido v. National Labor Relations Commission, 385 Phil. 999, 1013 (2000), citing Fernandez v.
National Labor Relations Commission, 285 SCRA 149 (1998).
23
Jpl Marketing Promotions v. Court of Appeals, National Labor Relations Commission, Noel Gonzales,
Ramon Abesa Iii AND Faustino Aninipot, G.R. No. 151966 July 8, 2005
 9. Computation for 13th month pay and service incentive leave.

“While computation for the 13th month pay should properly begin from the first day of
employment, the service incentive leave pay should start a year after commencement of
service, for it is only then that the employee is entitled to said benefit.”24

10. It should be made clear that when the law tilts the scale of justice in favor of
labor, it is but recognition of the inherent economic inequality between labor
and management; There may be cases where the circumstances warrant
favoring labor over the interests of management but never should the scale
be so tilted if the result is an injustice to the employer.

“The law in protecting the rights of the employees authorizes neither oppression nor self-
destruction of the employer. It should be made clear that when the law tilts the scale of
justice in favor of labor, it is but recognition of the inherent economic inequality between
labor and management. The intent is to balance the scale of justice; to put the two parties on
relatively equal positions. There may be cases where the circumstances warrant favoring
labor over the interests of management but never should the scale be so tilted if the result is
an injustice to the employer. Justitia nemini neganda est (Justice is to be denied to none).”25

24
Ibid
25
Philippine Geothermal, Inc. v. National Labor Relations Commission, 236 SCRA 371, 379 (1994).