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ART. 97. Definitions.
- As used in this Title:
( a)"Person"meansanindividual,partnership,association,corporation,businesstrust,legalrepresentatives,
or any organized group of persons.
( b)"Employer"includesanypersonactingdirectlyorindirectlyintheinterestofanemployerinrelationtoan
employee and shall include the government and all its branches, subdivisions and instrumentalities, all
government-owned or controlled corporations and institutions, as well as non-profit private institutions, or
organizations.
(c) "Employee" includes any individual employed by an employer.
( d)"Agriculture"includesfarminginallitsbranchesand,amongotherthings,includescultivationandtillage
of soil, dairying, the production, cultivation, growing and harvesting of any agricultural and horticultural
commodities, the raising of livestock or poultry, and any practices performed byafarmeronafarmasan
incident to or in conjunction with such farming operations, but does not include the manufacturing or
processing of sugar, coconuts, abaca, tobacco, pineapples or other farm products.
(e) "Employ" includes to suffer or permit to work.
( f)"Wage"paidtoanyemployeeshallmeantheremunerationorearnings,howeverdesignated,capableof
being expressed in terms of money, whether fixed or ascertained on a time, task, piece, or commission
basis, or other method of calculating the same, which ispayablebyanemployertoanemployeeundera
written or unwritten contract of employment forworkdoneortobedone,orforservicesrenderedortobe
rendered and includes the fair and reasonable value, as determined by the Secretary of Labor and
Employment, of board, lodging, or other facilities customarily furnished by the employer to the employee.
"Fair and reasonable value"shallnotincludeanyprofittotheemployer,ortoanypersonaffiliatedwiththe
employer.
ART. 100. Prohibition against elimination or diminution of benefits.
othinginthisBookshallbeconstruedtoeliminateorinanywaydiminishsupplements,orotheremployee
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benefits being enjoyed at the time of promulgation of this Code.
Art. 97: Notes and Discussion
Wage Salary
ompensation for manual labor, skilled or unskilled,
C enotes a higher degree of employment, or a
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paid at stated time and measured by the day, superior grade of services, and implies a position of
week,month or season. office.
● Pay for a lower and less responsible ● Suggestive of a larger and more permanent
character of employment or fixed compensation for more important
service
* * Wage and Salary are in essence synonymous
Includes:(C-F-C)
1. Co mmission
2. Fa
cilities
3. Co
mmodities/Supplements
Without theserequirements, employer cannot deductthe value from employee’s wage:(C-A-R)
1. Proof must be show that such facilities areCu stomarilyfurnished by trade
2. Provision of deductible facilities must be voluntarilyAc cepted in writing by the employee
3. Facilities must be charged at fair andReasonable value
age includes Facilities and Commodities
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Includes the fair and reasonable value for board, lodging,orotherfacilities.Employermayprovidefoodand
housing to his employees but he may deduct their values from employees’ wages.
Facilities Supplements
hall include articles or services for the benefit of the employee
S onstitute extra remuneration or special privileges or
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or his family but shall not include tools of the trade or articles or benefits given to or received by the laborers over and
service primarily for the benefit of the employer or necessary to
the conduct of the employer’s business. above their ordinary earnings or wages.
ecessary for the employer’s and his family’s existence and
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subsistence, so that by express provision of lawforms part of
the wageand when furnished by the employer are deductible
there from, since if they are not furnished, the laborer would
spend and pay for them just the same .
**Facilities are wage-deductible, supplements are not
alary distinguished from Gratuity
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Gratuity is something freely given; without recompense; a gift. Rendered fully out of the generosity of the
grantor.Notintendedtopayaworkerforactualservicesrendered.Purposeistorewardemployeeswhohave
rendered satisfactory and efficient service to the company.
air Day’s Wage for a Fair Day’s Labor
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Noworknopayunlessthelaborerwasable,willingandreadytoworkbutwaspreventedbymanagementor
was illegally locked out, suspended, or dismissed.
Equal pay Equal Work - In performing similar functions and responsibilities such as position and rank,
perception is that these employees perform equal work.
gricultural Work- Work on the soil and its harvest.
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Employed in operations other than purely agricultural work are deemed industrial employees.
Activities categorized as agricultural (T-F-I)
1. Tillage of soil, raising crops including discovery of plant pest and their eradication by means of
insecticides done in Bureau of Plant Industry Experimental Station
2. Business ofFishpond
3. Employees ofIn ternational Rice Research Institute
Songco vs. NLRC, March 23, 1990 Millares vs NLRC
acts:Private respondent F.E. Zuellig filed with the Department of Labor
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an application seeking clearance to terminate the services of petitioners Jose Songco,Romeo Cipres, and
Amancio Manuel. allegedly on the ground of retrenchment due to financial losses. This application was
seasonably opposed by petitioners alleging that the company isnotsufferingfromanylosses.Theyalleged
furtherthattheyarebeingdismissedbecauseoftheirmembershipintheunion.Atthelasthearingofthecase,
however,petitionersmanifestedthattheyarenolongercontestingtheirdismissal.Thepartiesthenagreedthat
thesoleissuetoberesolvedisthebasisoftheseparationpayduetopetitioners.Petitioners,whowereinthe
salesforceofZuelligreceivedmonthlysalariesofatleastP40,000.Inaddition,theyreceivedcommissionsfor
every sale they made.
The collective Bargaining Agreement provides: Retirement Gratuity, Reduction of personnel
here the termination of employment is due to retrenchment initiated by the employertopreventlossesor
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other similar causes, or where the employee suffers from a disease and his continued employment is
prohibitedbylaworisprejudicialtohishealthortothehealthofhisemployees,theemployeeshallbeentitled
to termination pay equivalent at least to his one month salary, or to one-half month pay for every year of
service, whichever is higher
ISSUE:
W/Nearnedsalescommissionsandallowancesshouldbeincludedinthemonthlysalaryofpetitionersfor
the purpose of computation of their separation pay.
ULING:YES,commissionsandallowancesshouldbeincluded.Petitioners'positionwasthatinarriving
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at the correct and legal amount of separation pay due them
cited Article 97(f) of theLabor Code includes commission as part on one's salary
( f)'Wage'paidtoanyemployeeshallmeantheremunerationorearnings,howeverdesignated,capableofbeingexpressedintermsof
money, whether fixed or ascertained onatime,task,piece,orcommissionbasis,orothermethodofcalculatingthesame,whichis
payable by an employer to an employee under a written or unwritten contract of employment for work done or to bedone,orfor
servicesrenderedortoberendered,andincludesthefairandreasonablevalue,asdeterminedbytheSecretaryofLabor,ofboard,
lodging,orotherfacilitiescustomarilyfurnishedbytheemployertotheemployee.'Fairreasonablevalue'shallnotincludeanyprofitto
the employer or to any person affiliated with the employer.
Zuellig argues that if it were really the intention of theLaborCodeaswellasitsimplementingrulesto
include commission in the computation of separation pay, it could have explicitly said so in clear and
unequivocal terms
rticle 97(f) by itself is explicit that commission is included in the definition of the term "wage".Ithasbeen
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repeatedly declared by the courts that where the law speaks in clear and categorical language,thereisno
room for interpretation or construction; there is only room for application
hedefinitionof'wage'providedinArticle96oftheCodecanbecorrectlystatedasageneraldefinition.Itis
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'wage'initsgenericsense.Acarefulperusalofthesamedoesnotshowanyindicationthatcommissionis
partofsalary.Wecansaythatcommissionbyitselfmaybeconsideredawage.Itcouldbededucedthatwage
isusedinitsgenericsenseandobviouslyreferstothebasicwageratetobeascertainedonatime,task,piece
or commission basis or other method of calculating the same.Itdoesnot,however,meanthatcommission,
allowances or analogous income necessarily forms part of the employee's salary.
" wages", "pay"and"salary"havethesamemeaning,andcommissionisincludedinthedefinitionof
"wage", the logical conclusion, therefore, is, in the computation of the separation pay of petitioners, their
salary base should include also their earned sales commissions.
eagreewiththeSolicitorGeneralthatgranting,ingratiaargumenti,thatthecommissionswereintheformof
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incentivesorencouragement,sothatthepetitionerswouldbeinspiredtoputalittlemoreindustryonthejobs
particularly assigned to them
he nature of the work of a salesman and the reason for such type of remuneration for services
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rendereddemonstrateclearlythatcommissionsarepartofpetitioners'wageorsalary.Wetakejudicial
noticeofthefactthatsomesalesmendonotreceiveanybasicsalarybutdependoncommissionsand
allowances or commissions alone, are part of petitioners' wage or salary although an
employer-employee relationship exists. Bearing inmindtheprecedingdiscussion,ifweadopttheopposite
viewthatcommissionsdonotformpartofwageorsalary,then,ineffect,Wewillbesayingthatthiskindof
salesmen do not receiveanysalaryandtherefore,notentitledtoseparationpayintheeventofdischarge
from employment.
he final consideration is, in carrying out and interpreting the Labor Code's provisions and its
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implementing regulations, the workingman's welfare should be the primordial and paramount
consideration.Thiskindofinterpretationgivesmeaningandsubstancetotheliberalandcompassionatespirit
ofthelawasprovidedforinArticle4oftheLaborCodewhichstatesthat"alldoubtsintheimplementationand
interpretation of the provisions of the Labor Code including its implementing rules and regulations shall be
resolved in favor of labor"
CCORDINGLY, the petition is hereby GRANTED. ThedecisionoftherespondentNationalLaborRelations
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CommissionisMODIFIEDbyincludingallowancesandcommissionsintheseparationpayofpetitioners
Jose Songco and Amancio Manuel.
Millares vs NLRC, March 29, 1999 (on facilities vs. supplements)
acts: Petitioners numbering one hundred sixteen (116) 1 occupied the positions of Technical Staff, Unit
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Manager, Section Manager, Department Manager, Division Manager and Vice President in the mill site of
respondentPaperIndustriesCorporationofthePhilippines(PICOP)inBislig,SurigaodelSur.In1992PICOP
suffered a major financial setback allegedly brought about by the joint impact of restrictive government
regulations on logging and the economic crisis. Toavertfurtherlosses,itundertookaretrenchmentprogram
and terminated the services of petitioners. Accordingly, petitioners received separation pay computed at the
rateofone(1)monthbasicpayforeveryyearofservice.Believinghoweverthattheallowancestheyallegedly
regularly receivedonamonthlybasisduringtheiremploymentshouldhavebeenincludedinthecomputation
thereof they lodged a complaint for separation pay differentials.
The allowances in question pertained to the following —
1.Staff/Manager’s Allowance—
espondent PICOP provides freehousingfacilitiestosupervisoryandmanagerialemployeesassigned
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in Bislig. The privilege includes free water and electric consumption. Owing however to shortage of such
facilities,itwasconstrainedtograntStaffallowanceinsteadtothosewholiveinrentedhousesoutsidebutnear
the vicinity of the mill site. But the allowance ceases whenever a vacancy occurs inthecompany’shousing
facilities. Theformergranteeisthendirectedtofillthevacancy.ForUnit,SectionandDepartmentManagers,
respondent PICOP gives an additional amount to meet the same kind of expenses called Manager’s allowance.
2.Transportation Allowance—
o relieve respondent PICOP’s motor pool in Bislig from a barrage of requests forcompanyvehiclesandto
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stabilize company vehicle requirements it grants transportation allowance tokeyofficersandManagers
assignedinthemillsitewhousetheirownvehiclesintheperformanceoftheirduties.Itisaconditional
rantsuchthatwhentheconditionsnolongerobtain,theprivilegeisdiscontinued.Therecipientsofthiskindof
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allowance are required to liquidate it by submitting a report with a detailed enumeration of expenses incurred.
3. Bislig Allowance—
heBisligAllowanceisgiventoDivisionManagersandcorporateofficersassignedinBisligonaccount
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ofthehostileenvironmentprevailingtherein.ButoncetherecipientistransferredelsewhereoutsideBislig,
the allowance ceases.
pplyingArt.97,par.(f),oftheLaborCodewhichdefines"wage,"theExecutiveLaborArbiteropinedthatthe
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subject allowances, being customarily furnished by respondent PICOP and regularly receivedbypetitioners,
formedpartofthelatter’swages.Resolvingthecontroversyfromanotherangle,onthestrengthoftherulingin
Santos v.NLRC2andSorianov.NLRC3thatinthecomputationofseparationpayaccountshouldbetaken
not just of the basic salary but also of the regular allowances that the employee had been receiving, he
concluded that the allowances should be included in petitioners’ base pay. Thus respondent PICOP was
ordered on 28 April 1994 to pay petitioners Four Million Four Hundred Eighty-One Thousand Pesos
(P4,481,000.00) representing separation pay differentials plus ten per cent (10%) thereof as attorney’s fees. 4
heNationalLaborRelationsCommission(NLRC)didnotsharetheviewoftheExecutiveLaborArbiter.On7
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October1994itsetasidetheassaileddecisionbydecreeingthattheallowancesdidnotformpartofthesalary
base used in computingseparationpay.Itsrulingwasbasedonthefindingthatthecasesrelieduponbythe
Executive Labor Arbiter were inapplicable since they involved illegal dismissal where separation pay was
granted in lieu of reinstatement which was no longer feasible. Art.97,par.(f),oftheLaborCode,theNLRC
likewise found that petitioners’allowances were contingency-based and thus not included in their salaries.
Inthispetitionforcertiorari,petitionerssubmitthattheirallowancesareincludedinthedefinitionof"facilities"in
Art. 97, par. (f), of the Labor Code, being necessary and indispensable for their existence andsubsistence.
Furthermore theyclaimthattheiravailmentofthemonetaryequivalentofthose"facilities"onamonthlybasis
was characterized by permanency, regularity and customariness.
hereisnoshowingofgraveabuseofdiscretiononthepartoftheNLRC.Incaseofretrenchmenttoprevent
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losses,Art.283oftheLaborCodeimposesontheemployeranobligationtogranttotheaffectedemployees
separation pay equivalent to one (1) month pay or at least one-half month pay for every year of service,
whicheverishigher.Sincethelawspeaksof"pay,"thequestionarises,"Whatexactlydoesthetermconnote?"
We correlate Art. 283 with Art. 97 of the same Code on definition of terms. "Pay" is notdefinedthereinbut
"wage."InSongcotheCourtexplainedthatbothwords(aswellassalary)generallyrefertooneandthesame
meaning,i.e.,arewardorrecompenseforservicesperformed.Specifically,"wage"isdefinedinletter(f)asthe
remuneration or earnings,howeverdesignated,capableofbeingexpressedintermsofmoney,whetherfixed
or ascertainedonatime,task,piece,orcommissionbasis,orothermethodofcalculatingthesame,whichis
payablebyanemployertoanemployeeunderawrittenorunwrittencontractofemploymentforworkdoneor
to be done, or for services rendered or to be rendered and includes the fair and reasonable value, as
determined by the Secretary of Labor, of board, lodging, or other facilities customarily furnished by the
employer to the employee.
einviteattentiontotheabove-underlinedclause.Stateddifferently,whenanemployercustomarilyfurnishes
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his employee board, lodging or other facilities, the fair and reasonable value thereof, as determined by the
Secretary of Labor and Employment, is included in "wage." In order to ascertain whether the subject
allowances form part of petitioner’s "wages," we divide the discussion on the following — "customarily
furnished;""board,lodgingorotherfacilities;"and,"fairandreasonablevalueasdeterminedbytheSecretary
of Labor.
"Customary" is founded on long-established and constant practice connoting regularity. 14Thereceiptofan
allowanceonamonthlybasisdoesnotipsofactocharacterizeitasregularandformingpartofsalarybecause
thenatureofthegrantisafactorworthconsidering.WeagreewiththeobservationoftheOfficeoftheSolicitor
General thatthe subject allowances were temporarily, not regularly, received by petitioners because —
In the case of the housing allowance, once a vacancy occurs in the company-provided housing
accommodations, the employee concerned transfers to the company premises and his housing
allowance is discontinued. . .
ntheotherhand,thetransportationallowanceisintheformofadvancesforactualtransportationexpenses
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subject to liquidation . . . given only to employees who have personal cars.
heBisligallowanceisgiventoDivisionManagersandcorporateofficersassignedinBislig,SurigaodelNorte.
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Once the officer is transferred outside Bislig, the allowance stops. 16
eaddthatintheavailabilityofthetransportationallowance,respondentPICOPsetanotherrequirementthat
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the personal cars be used by the employees in the performance of their duties. When the conditions for
availment ceased to exist, the allowance reached the cutoff point.
lthoughitisquiteeasytocomprehend"board"and"lodging,"itisnotsowith"facilities."ThusSec.5,RuleVII,
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Book III, of the Rules Implementing the Labor Code gives meaning to the term as including articles or
ervices for the benefit of the employee or his family but excluding tools of the trade or articles or
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service primarily for the benefit of the employer or necessary to the conduct of the employer’s
business.
he Staff/Manager’s allowance may fall under "lodging" but the transportationandBisligallowances
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are not embraced in "facilities'' on the main consideration that they are granted as well as the
Staff/Manager’s allowance for respondent PICOP’s benefit and convenience, i.e., to insure that petitioners
renderqualityperformance.Indeterminingwhetheraprivilegeisafacility,thecriterionisnotsomuchit'skind
but its purpose. That the assailed allowances were for the benefit and convenienceofrespondentcompany
was supported by the circumstance that they were not subjected to withholding tax. Revenue Audit Memo
Order No. 1-87 pertinently provides —
3.2 . . . transportation, representation or entertainment expenses shall not constitute taxable compensation if
( a)Itisfornecessarytravelingandrepresentationorentertainmentexpensespaidorincurredbytheemployee
in the pursuit of the trade or business of the employer, and
( b) The employee is required to, and does, make an accounting/liquidation for such expense inaccordance
with the specific requirements of substantiation for such category or expense.
oard and lodging allowances furnishedtoanemployeenotinexcessofthelatter’sneedsandgivenfreeof
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charge,constituteincometothelatterexceptifsuchallowancesorbenefitsarefurnishedtotheemployeefor
theconvenienceoftheemployerandasnecessaryincidenttoproperperformanceofhisdutiesinwhichcase
such benefits or allowances do not constitute taxable income.
heSecretaryofLaborandEmploymentunderSec.6,RuleVII,BookIII,oftheRulesImplementingtheLabor
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Code may fromtimetotimefixinappropriateissuancesthe"fairandreasonablevalueofboard,lodgingand
other facilities customarily furnished by an employer to his employees." Petitioners’ allowances do not
represent such fair and reasonable value as determined by the proper authority simply because the
Staff/Manager’sallowanceandtransportationallowancewereamountsgivenbyrespondentcompanyinlieuof
actualprovisionsforhousingandtransportationneedswhereastheBisligallowancewasgiveninconsideration
of being assigned to the hostile environment then prevailing in Bislig
he inevitable conclusion is that, as reached by the NLRC, subject allowances did not form part of
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petitioners’ wages.
In Santos the Court decreed that in the computation of separation pay awarded in lieu of reinstatement,
accountmustbetakennotonlyofthebasicsalarybutalsooftransportationandemergencylivingallowances.
Later, the Court in Soriano, citing Santos, was general in its holding that the salary base properly used in
computingseparationpaywherereinstatementwasnolongerfeasibleshouldincludenotjustthebasicsalary
but also the regular allowances that the employee had been receiving. Insular merely reiterated the
aforementionedrulings.Therationaleisnotdifficulttodiscern.Itistheobligationoftheemployertopayan
illegally dismissed employee the whole amount of his salaries plus all other benefits, bonuses and
general increasestowhichhewouldhavebeennormallyentitledhadhenotbeendismissedandhad
notstoppedworking.Thesameholdstrueincaseofretrenchedemployees.AndthusweappliedInsularand
Soriano in Planters in the computation of separationpayofretrenchedemployees.Songcolikewiseinvolved
retrenchment and was relied upon by Planters, Soriano and Santos in determining the proper amount of
separation pay. As culled from the foregoing jurisprudence, separation pay when awarded to an illegally
dismissedemployeeinlieuofreinstatementortoaretrenchedemployeeshouldbecomputedbasednotonly
onthebasicsalarybutalsoontheregularallowancesthattheemployeehadbeenreceiving.Butinviewofthe
previous discussion that thedisputedallowanceswerenotregularlyreceivedbypetitionersherein,therewas
no reason at all for petitioners to resort to the above cases.
either is Kneebone applicable, contrary to the finding of the NLRC, because of the difference in factual
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circumstances. In Kneebone, the Court was tasked to resolve the issue whether the representation and
transportationallowancesformedpartofsalaryastobeconsideredinthecomputationofretirementbenefits.
Therulingwasinthenegativeonthemaingroundthattheretirementplanofthecompanyexpresslyexcluded
such allowances from salary.
HEREFORE, the petition is DISMISSED. The resolution of public respondent National Labor Relations
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Commission dated 7 October1994holdingthattheStaff/Manager’s,transportationandBisligallowancesdid
notformpartofthesalarybaseusedincomputingtheseparationpayofpetitioners,aswellasitsresolution
dated 26 September 1995 denying reconsideration, is AFFIRMED. No costs.
Cases in line with Art. 100
American Wire Union vs. American Wire (GR 155059)
acts: American Wire and Cable Co., Inc., is acorporationengagedinthemanufactureofwiresandcables.
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There are two unions in this company, the American Wire and Cable Monthly-Rated Employees Union
(Monthly-Rated Union) and the American Wire and Cable Daily-Rated Employees Union (Daily-Rated Union).
On 16 February 2001, an original action was filed before the NCMB of the Department of Labor and
Employment.Theyallegedthattheprivaterespondent,withoutvalidcause,suddenlyandunilaterallywithdrew
and denied certain benefits and entitlements which they have long enjoyed. These are the ff:
a. Service Award;
b.35%premiumpayofanemployee’sbasicpayfortheworkrenderedduringHolyMonday,HolyTuesday,Holy
Wednesday, December 23, 26, 27, 28 and 29;
c. Christmas Party; and
d. Promotional Increase.
promotionalincreasewasaskedbythepetitionerforfifteen(15)ofitsmemberswhoweregivenorassigned
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new job classifications. According to petitioner, the new job classifications were inthenatureofapromotion,
necessitating the grant of an increase in the salaries of the said 15 members.
motionforreconsiderationwasfiledbybothunionswheretheyallegedthattheVoluntaryArbitratormanifestly
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erredinfindingthatthecompanydidnotviolateArticle100oftheLaborCode,asamended,whenitunilaterally
withdrew the subjectbenefits,andwhennopromotionalincreasewasgrantedtotheaffectedemployees.The
motion for reconsideration is hereby DENIED for lack of merit. Dissatisfied with the court a quo’s ruling,
petitioner instituted the instant special civil action for certiorari.
ISSUE: Whether or not a private respondentisguiltyofviolatingArticle100oftheLaborCode,asamended,
when the benefits/entitlements given to the members of petitioner union were withdrawn.
ULING:TheSupremeCourtmaybrushasidetheproceduralbarrierandtakecognizanceofthepetitionasit
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raises an issue of paramount importance.
rticle 100 of the LaborCodeprovides:ART.100.PROHIBITIONAGAINSTELIMINATIONORDIMINUTION
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OF BENEFITS. – Nothing in this Book shall be construed to eliminate or in any way diminish
supplements, or other employee benefits being enjoyed at the time of promulgation of this Code.
hepetitionersubmitsthatthewithdrawaloftheprivaterespondentofthebenefitssuchas35%premiumpay
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for selected days during the Holy Week and Christmas season, the holding of the Christmas Party and its
incidentalbenefits,andthegivingofserviceawardsviolatedArticle100oftheLaborCode.Thegrantofthese
benefitswasacustomarypracticethatcannolongerbeunilaterallywithdrawnbyprivaterespondentwithoutthe
tacit consent of the petitioner. The benefits in question were given by the respondent to the petitioner
consistently, deliberately, and unconditionallysincetimeimmemorial.Thebenefits/entitlementswerenotgiven
topetitionerduetoanerrorininterpretation,oraconstructionofadifficultquestionoflaw,butsimply,thegrant
has been a practice over a long period of time. As such, it cannot be withdrawn from the petitioner at
respondent’s whim and caprice, and without the consent of the former.Thebenefitsgivenbytherespondent
cannotbeconsideredasa"bonus"astheyarenotfoundedonprofit.Evenassumingthatitcanbetreatedasa
"bonus,"thegrantofthesame,byreasonofitslongandregularconcession,mayberegardedaspartofregular
compensation.
ith respect to the fifteen (15) employees who are members of petitioner union that were given new job
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classifications Salary adjustment is a must due to their promotion.
n the matter of the withdrawal of the service award,thepetitionerarguesthatitistheemployee’slengthof
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service which is taken as a factor inthegrantofthisbenefit,andnotwhetherthecompanyacquiredprofitor
not.Inanswertoallthese,therespondentcorporationaversthatthegrantofallsubjectbenefitshasnot
ripenedintopracticesothattheemployeesconcernedcanclaimademandablerightoverthem.Thegrantof
these benefits was conditional based upon the financial performance of the company and that
conditions/circumstances that existedbeforehaveindeedsubstantiallychangedtherebyjustifyingthe
discontinuance of said grants. The company’s financial performance was affected by the recent political
turmoilandinstabilitythatledtheentirenationtoableedingeconomy.Hence,itonlynecessarilyfollowsthatthe
company’s financial situation at present is already very much different from where it was three or four years ago.
he respondent company likewise asseverates that the 15 members of petitioner union were not
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actually promoted. There was only a realignment of positions.
eterminationmustbefirstmadeonwhetherthebenefits/entitlementsareinthenatureofabonusornot,
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and assuming they are so, whether they are demandable and enforceable obligations.
bonus is an amount granted and paid to an employee for his industry and loyaltywhichcontributedtothe
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success of the employer’s business and made possible the realization of profits. It is an act of generosity
grantedbyanenlightenedemployertospurtheemployeetogreatereffortsforthesuccessofthebusinessand
r ealizationofbiggerprofits.Th egrantingofabonusisamanagementprerogative.Basedontheforegoing
pronouncement,itisobviousthatthebenefits/entitlementssubjectsoftheinstantcaseareallbonuseswhich
were given by theprivaterespondentoutofitsgenerosityandmunificence.Theadditional35%premium
pay are allinexcessofwhatthelawrequireseachemployertogiveitsemployees.Thegrantingofthesame
wasamanagementprerogative,which,whenevermanagementseesnecessary,maybewithdrawn,unless
they have been made a part of the wage or salary or compensation of the employees.
anthesebonusesbeconsideredpartofthewageorsalaryorcompensationmakingthemenforceable
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obligations? NO. The Court does not believe so.
or abonustobeenforceable,itmusthavebeenpromisedbytheemployerandexpresslyagreedupon
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bytheparties,oritmusthavehadafixedamoun1andhadbeenalongandregularpracticeonthepart
of the employer.
hebenefits/entitlementsinquestionwereneversubjectsofanyexpressagreementbetweentheparties.They
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were never incorporated in the Collective Bargaining Agreement (CBA).
he Christmas parties and its incidental benefits, and the giving of cash incentive together with the service
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award cannot be said to have fixed amounts. the grant of these two aforementioned bonuses cannot be
considered to have been the private respondent’s long and regular practice. To be considered a "regular
practice,"thegivingofthebonusshouldhavebeendoneoveralongperiodoftime,andmustbeshowntohave
beenconsistentanddeliberate.Thedowntrendinthegrantofthesetwobonusesovertheyearsdemonstrates
that there is nothing consistent about it. We agree with the Voluntary Arbitrator that the same was merely
sponsored by the respondent corporation out of generosity and that the same is dependent on the financial
performance of the company for a particular year
5% premium pay was deliberately given and the same was inexcessofthatprovidedbythelaw,thesame
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howeverdidnotripenintoacompanypracticeonaccountofthefactthatitwasonlygrantedfortwo(2)years
andwiththeexpressreservationfromrespondentcorporation’sownerthatitcannotcontinuetorantthesamein
view of the company’s current financial situation.
Toholdthatanemployershouldbeforcedtodistributebonuseswhichitgrantedoutofkindnessisto
penalize him for his past generosity.
The grant of cash incentive together with the service award are all bonuses which are neither
demandable nor enforceable obligations of the private respondent.
ntheallegedpromotionof15membersofthepetitionerunionthatshouldwarrantanincreaseintheirsalaries,
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ConsideringthattheUnionwasunabletoadduceproofthatapromotionindeedoccur[ed]withrespecttothe15
employees, the Daily Rated Union’s claim for promotional increase likewise fall[s] there being no promotion
established under the records at hand.
Lepanto Ceramics Inc. (GR 180866)
ACTS: Petitioner Lepanto Ceramics, Incorporated is adulyorganizedcorporationexistingandoperatingby
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virtue of Philippine Laws. Its business is primarilytomanufacture,make,buyandsell,onawholesalebasis,
among others, tiles, marbles, mosaics andothersimilarproducts.RespondentLepantoCeramicsEmployees
Association (respondent Association)isalegitimatelabororganizationdulyregisteredwiththeDepartmentof
Labor and Employment. It is the sole and exclusive bargaining agent in the establishment of petitioners.
In December 1998, petitioner gave a ₱3,000.00 bonus to its employees,in September 1999, petitioner and
respondent Association entered into a Collective Bargaining Agreement (CBA) which provides for, among
others, the grant of a Christmas gift package/bonus to the members of the respondent Association. The
Christmas bonus was one of the enumerated "existing benefits, practice of traditional rights" which "shall
remain in full force and effect."
Inthesucceedingyears,1999,2000and2001,thebonuswasnotincash.Instead,petitionergaveeachofthe
members of respondent Association Tile Redemption Certificates equivalentto₱3,000.00.Thebonusforthe
year 2002 is the root of the present dispute. Petitioner gave a year-end cash benefit of Six HundredPesos
(₱600.00) andofferedacashadvancetointerestedemployeesequivalenttoone(1)monthsalarypayablein
oneyear.RespondentAssociationobjectedtothe₱600.00cashbenefitandarguedthatthiswasinviolationof
the CBA it executed with the petitioner.
espondent Associationinsistedthatithasbeenthetraditionalpracticeofthecompanytograntitsmembers
R
Christmasbonusesduringtheendofthecalendaryear,eachintheamountof₱3,000.00asanexpressionof
gratitude to the employees for their participation in the company’s continued existence in the market. The
bonuswaseitherincashorintheformofcompanytiles.In2002,inaspeechduringtheChristmascelebration,
one of the company’s top executivesassuredtheemployeesofsaidbonus.However,theHumanResources
DevelopmentManagerinformedthemthatthetraditionalbonuswouldnotbegivenasthecompany’searnings
were intended for the payment of itsbankloans.RespondentAssociationarguedthatthiswasinviolationof
their CBA.
etitioner averredthatthecomplaintfornonpaymentofthe2002Christmasbonushadnobasisasthesame
P
wasnotademandableandenforceableobligation.Itarguedthatthegivingofextracompensationwasbased
on the company’s available resources for a given year and the workers are not entitled to a bonus if the
company does not make profits.
etitioneralsoaverredthattheCBAprovisionona"Christmasgift/bonus"referstoalternativebenefits.Finally,
P
petitioner emphasized that even if the CBA contained an unconditional obligation to grant the bonus to the
respondentAssociation,thepresentdifficulteconomictimeshadalreadylegallyreleasedittherefrompursuant
to Article 1267 of the Civil Code.
heVoluntaryArbitratorrenderedaDecisiondated2June2003,declaringthatpetitionerisboundtogrant
T
each of its workers a Christmas bonus of ₱3,000.00 for the reasonthatthebonuswasgivenpriortothe
effectivityoftheCBAbetweenthepartiesandthatthefinanciallossesofthecompanyisnotasufficientreason
toexemptitfromgrantingthesame.ItstressedthattheCBAisabindingcontractandconstitutesthelaw
between the parties.
Petitioner elevated the case to the Court of Appeals
Inthecaseatbar,itisindubitablethatpetitionerofferedprivaterespondentaChristmasbonus/giftin1998or
before the execution of the 1999 CBA which incorporated the said benefit as a traditional right of the
employees.Hence,thegrantofsaidbonustoprivaterespondentcanbedeemedapracticeasthesamehas
not been givenonlyinthe1999CBA.Apparently,thisisthereasonwhypetitionerspecificallyrecognizedthe
grant of a Christmas bonus/gift as a practice or tradition as stated in the CBA
heargumentofpetitionerthatthegivingofaChristmasbonusisamanagementprerogativeholdsnowater.
T
TherewerenoconditionsspecifiedintheCBAforthegrantofsaidbenefitcontrarytotheclaimofpetitioner
thatthesameisjustifiedonlywhenthereareprofitsearnedbythecompany.AscanbegleanedfromtheCBA,
thepaymentofChristmasbonuswasnotcontingentupontherealizationofprofits.Itdoesnotstatethatifthe
company derives no profits, therearenobonusestobegiventotheemployees.Infine,thepaymentthereof
was not related to the profitability of business operations.
ISSUE:W/N petitioner is bound to grant each of its workers a Christmas bonus of ₱3,000.00
ULING:YES.
R
CA upholds the rulings.
By definition, a"bonus"isagratuityoractofliberalityofthegiver.Itissomethinggiveninadditiontowhatis
ordinarilyreceivedbyorstrictlyduetherecipient.Abonusisgrantedandpaidtoanemployeeforhisindustry
and loyalty which contributed tothesuccessoftheemployer’sbusinessandmadepossibletherealizationof
profits. A bonus is also granted by an enlightened employer to spur the employee to greater efforts for the
success of the business and realization of bigger profits.
Generally,abonusisnotademandableandenforceableobligation.Forabonustobeenforceable,itmust
havebeenpromisedbytheemployerandexpresslyagreeduponbytheparties.Giventhatthebonusinthis
case is integrated in the CBA, the same partakes the nature of a demandable obligation.
ItisafamiliarandfundamentaldoctrineinlaborlawthattheCBAisthelawbetweenthepartiesandtheyare
obliged to comply with its provisions.This principle stands strong and true in the case at bar.
etitionersupposedlycontinuedtoincurlossesintheyears200029and2001.Stillandall,thisdidnotdeterit
P
fromhonoringtheCBAprovisiononChristmasbonusasitcontinuedtogive₱3,000.00eachtothemembersof
the respondent Association in the years 1999, 2000 and 2001.
llgiven,businesslossesareafeeblegroundforpetitionertorepudiateitsobligationundertheCBA.
A
Theruleissettledthatanybenefitandsupplementbeingenjoyedbytheemployeescannotbereduced,
diminished,discontinuedoreliminatedbytheemployer.Theprincipleofnon-diminutionofbenefitsis
foundedontheconstitutionalmandatetoprotecttherightsofworkersandtopromotetheirwelfareand
to afford labor full protection
Art. 100: Notes and Discussion
Non-Diminution of Benefit when Applicable: (CUP-E)
1. The practice isCo nsistent and deliberate
2. The diminution or discontinuance is doneUn ilaterally by the employer
3. The grant of the benefit is founded on a policy or has ripened into aPr actice for a long period.
4. The practice is not due to Er ror intheconstructionorapplicationodadoubtfulordifficultquestionof
law
onstitutional Basis
C
Any benefit and supplement being enjoyed by employees cannot be reduced, diminished, discontinued or
eliminated by the employer. The principle of non-diminution of benefits is founded on the Constitutional
mandate to“protect the rights of workers and promote their welfare” and “to afford labor full protection”
hy apply Art. 100 long after promulgation of the Labor Code on May 1 1974?
W
Itisintendedtoprotectorpreservethosebenefitsdespitethecode’sintroductionofnewstatutorybenefitsand
imposition of minimum wage. Art. 100referssolelytoothernon-diminutionofbenefitsenjoyedatthetimeof
promulgation of the Labor Code. Nevertheless ,“mutuality of contract” principle in Article 1308 ofCivilCode
justifies non-diminution of employment benefits. EM-REL is a contractualrelationshipbasedonexpressand
implied terms(not expressly agreed upon but freely, voluntarily, and consistently extended to employees.
Exception to the Non-Diminution Rule: (CoNWaB-ReCop)
1. Correction of error
2. Ne gotiated benefits
3. Wage order compliance
4. Be nefits on reimbursement basis
5. Reclassification of position
6. Co ntingent benefits of conditional bonus
7. Pr oductivity incentives
orrection of Error
C
If it is a past error that is being corrected, no vested rightmaybesaidtohavearisennoranydiminutionof
benefit under Article 100 of the Labor Code may be said to have resulted by virtue of the correction.
egotiated Benefits
N
ThosecontainedintheCBAarenotwithintheprohibitionofart.100becauseasproductsofbilateralcontract,
they can only be eliminated or diminished bilaterally. The law forbids modification done unilaterally.
Wage Order Compliance
thegivingofacross-the-boardsalaryincreasessoastorectifyasalarydistortioncausedbycompliancewitha
wage order cannotbesaidtohaveripenedintoacompanypractice.Hence,ifthereisnosalarydistortionto
cure
age Order Compliance
W
Thegivingofacross-the-boardsalaryincreasessoastorectifyasalarydistortioncausedbycompliancewitha
wage order cannotbesaidtohaveripenedintoacompanypractice.Hence,ifthereisnosalarydistortionto
cure.
enefit on Reimbursement Basis
B
perdiemisadailyallowancegivenforeachdaywhenanofficeroremployeeisawayfromhishomebase.Itis
intendedtocoverthecostoflodgingandsubsistenceofofficersandemployeeswhenondutyoutsideoftheir
permanent station. The monthly ration of gasoline given to certain managerial employees is not part of the
employee's basic salary.
eclassification of Position; Promotion
R
BecauseofthereclassificationthepositionholderstherebyloseovertimepayandotherbenefitsunderArticles
82 to 96, but Article 100 is not violated. Promotion produces the same effect. But promotion and position
reclassification must be done in good faith.
Contingent or Conditional Benefits; Bonus
eitherdoestheruleunderArticle100applytoabenefitwhosegrantdependsontheexistenceofcertainconditions,so
N
that the benefit is not demandable if those preconditions are absent.
ifitisanadditionalcompensationwhichtheemployerpromisedandagreedtogivewithoutanyconditionsimposedforits
payment,suchassuccessofbusinessorgreaterproductionoroutput,thenitispartofthewage.Butifitispaidonlyif
profits are realized on a certain amount of productivity achieved, it cannot be considered part of the wages.
or a bonus to be enforceable, itmusthavebeenpromisedbytheemployerandexpresslyagreedbytheparties,orit
F
must have had a fixed amount and had been a long and regular practice on the part of the employer.
quity or Long Practice as Basis of Bonus
E
Evenifabonusisnotdemandablefornotformingpartofthewage,salaryorcompensationoftheemployee,
the same may nevertheless be granted on equitable considerations.
ervices rendered as basis of bonus
S
Article 6 of the Civil Code renders a quitclaim agreement void ab initio where the quitclaim obligates the
workers concerned to forego their benefits while at the same timeexemptingtheemployerfromanyliability
thatitmaychoosetoreject.ThisrunscountertoArticle22oftheCivilCodewhichprovidesthatnooneshall
be unjustly enriched at the expense of another.
.D. NO. 851: THIRTEENTH-MONTH PAY
P
Astatutorygrantwhichcreatesanimaginarythirteenthmonthandobligesemployerstopaytheemployeesfor
that imaginary month.
.D. No. 851, issued during the martial law regime, requires all employers to pay all their rank-and-file
P
employees receiving a basic salary of not more than PI ,000 a month, regardless of the nature of the
employment, a 13th-month pay not later than December 24 of every year.
1000 Salary Ceiling Removed
P
OnAugust13,1986,PresidentAquinoissuedMemorandumOrderNo.28toremovetheP1.000salaryceiling,
thus entitling to the 13th-month pay all rank-and-file employees, regardless of salary rate.
Computation of 13th-Month Pay;
"Thirteenth-Month Pay shall mean one-twelfth (1/12 ) of the basic salary of an employeewithinacalendar
year."
hat does "basic salary" include?
W
"Basic salary shall include all remunerations or earnings paid by an employer to an employee for services
rendered but may not include cost-of-living allowances granted pursuant to Presidential Decree No. 525 or
LetterofInstructionsNo.174,profit-sharingpaymentsandallallowancesandmonetarybenefitswhicharenot
consideredorintegratedaspartoftheregularorbasicsalaryoftheemployeeatthetimeofthepromulgation
oftheDecreeonDecember16,1975."overtimepayearningsandotherremunerationsareexcludedaspartof
the basic salary and in the computation of the 13th-month pay."
Inclusions by Practice or Agreement
TheitemsexcludedbytheDecreemaybeincludedthroughestablishedpracticeoragreementbindingonthe
employer. We [Supreme Court] have held that this act, which was favorable to the employees though not
conformingtolaw,hasripenedintoapracticeandthereforecannolongerbewithdrawn,reduced,diminished,
discontinued or eliminated.
ales commissions, on the other hand, such as those paid in Duplicators, are intimately related or directly
S
proportional to the extent or energy of an employee's endeavors. Commissions are paid upon the specific
resultsachievedbyasalesmanemployee.Itisapercentageofthesalesclosedbyasalesmanandoperates
as an integral part of such salesman's basic pay.
istressed Employer
D
TherulesandregulationsimplementingPresidentialDecreeNo.851providethatadistressedemployershall
qualify for exemption from the requirement of the decreeonlyuponpriorauthorizationfromtheSecretaryof
Labor and Employment.
on Strikeable
N
Differenceofopiniononhowtocomputethe13th-monthpaydoesnotjustifyastrike;inotherwords,itisanon
strikeable issue and a strike held on that ground is illegal.
MATERNITY LEAVE UNDER SSS LAW
EPUBLIC ACT No. 1161: Social Security Law
R
ection 14-A. Maternity Leave Benefit. — A covered female employee who has paid at least three monthly maternity
S
c ontributions in the twelve-month period preceding the semester of her childbirth, abortion, or miscarriage and who is currently
employedshallbepaidadailymaternitybenefitequivalenttoonehundredpercentofherpresentbasicsalary,allowancesandother
benefits or the cash equivalents of such benefits for sixty days subject to the following conditions:
( a)Thattheemployeeshallhavenotifiedheremployerofherpregnancyandtheprobabledateofherchildbirthwhichnoticeshallbe
transmitted to the SSS in accordance with the rules and regulations it may provide;
( b)Thatthepaymentshallbeadvancedbytheemployerintwoequalinstallmentswithinthirtydaysfromthefilingofthematernity
leave application;
(c) That in case of caesarian delivery, the employees shall be paid the daily maternity benefit for seventy-eight days;
( d) That payment of daily maternity benefits shall beabartotherecoveryofsicknessbenefitsprovidedbythisActforthesame
compensable period of sixty days for the same childbirth, abortion, or miscarriage;
(e) That the maternity benefits provided under this section shall be paid only for the first four deliveries after March 13, 1973;
( f)ThattheSSSshallimmediatelyreimbursetheemployerofonehundredpercentoftheamountofmaternitybenefitsadvancedto
the employee by the employer upon receipt of satisfactory proof of such payment and legality thereof; and
( g)Thatifanemployeeshouldgivebirthorsufferabortionormiscarriagewithouttherequiredcontributionshavingbeenremittedfor
herbyheremployertotheSSS,orwithoutthelatterhavingbeenpreviouslynotifiedbytheemployeroftimeofthepregnancy,the
employershallpaytotheSSSdamagesequivalenttothebenefitswhichsaidemployeewouldotherwisehavebeenentitledto,and
theSSSshallinturnpaysuchamounttotheemployeeconcerned.(AsamendedbySec.7,P.D.No.1202,S-1977;Sec.11,P.D.No.
1636, S-1979; and R.A. 7322)
ART. 133. MATERNITY LEAVE BENEFITS (LABOR CODE)
( a)Everyemployershallgranttoanypregnantwomanemployee,whohasrenderedanaggregateserviceofatleastsix(6)monthsfor
thelasttwelve(12)months,maternityleaveofatleasttwo(2)weekspriortotheexpecteddateofdeliveryandanotherfour(4)weeks
after normal delivery or abortion with full pay based on her regular or average weeklywages.Theemployermayrequirefromany
womanemployeeapplyingformaternityleavetheproductionofamedicalcertificatestatingthatdeliverywillprobablytakeplacewithin
two weeks.
( b)Thematernityleaveshallbeextendedwithoutpayonaccountofillnessmedicallycertifiedtoariseoutofthepregnancy,delivery,
abortion, or miscarriage, which renders the woman unfit for work, unless she has earnedfromwhichsuchextendedleavemaybe
charged.
(c)MaternityleaveprovidedinthisArticleshallbepaidbytheemployeronlyforthefirstfour(4)deliveriesbyawomanemployeeafter
the effectivity of this Code.
ualifications for Entidement to Maternity Benefit
Q
The following are the qualifications for entitlement to maternity benefits:
1. The female member should be employed at the time of delivery, miscarriage or abortion.
2. She must have given the required notification to the SSS thru her employer.
3.Heremployermusthavepaidatleastthree(3)monthsofmaternitycontributionswithinthe12-monthperiod
immediately before the semester of contingency.
arried or Unmarried
M
Every pregnant woman in the private sector, whether married or unmarried, is entitled to maternity leave
benefits.
ot Part of 13th-Month Pay
N
Maternity benefits, like other benefits granted by the SSS, are granted to employees in lieu of wages and,
therefore, may not be included in computing the employee's 13th-month pay for the calendar year.
"BATTERED WOMAN LEAVE"
R.A. No. 9262 (the "AVAWC law")
" Battered Woman Syndrome" refers to a scientifically defined pattern of psychological and behavioral
symptoms found in women living in battering relationships as a result of cumulative abuse.
ECTION43.EntitledtoLeave.–VictimsunderthisActshallbeentitledtotakeapaidleaveofabsenceup
S
to ten (10) days in addition to other paid leaves under the Labor Code and Civil Service Rules and
Regulations, extendible when the necessity arises as specified in the protection order.
nyemployerwhoshallprejudicetherightofthepersonunderthissectionshallbepenalizedinaccordance
A
withtheprovisionsoftheLaborCodeandCivilServiceRulesandRegulations.Likewise,anemployerwho
shallprejudiceanypersonforassistingaco-employeewhoisavictimunderthisActshalllikewisebeliable
for discrimination.
" Anti-violenceAgainstWomenandtheirChildrenActof2004,"approvedonMarch8,2004—allowsthevictim
of violence, which may be physical,sexualorpsychological,toapplyfortheissuanceofa"protectionorder"
thatwillshieldherfromfurtherviolenceandprovideherrelatedreliefs.Ifsuchavictimisanemployeesheis
entitledtoapaidleaveofuptoten^daysinadditiontootherpaidleavesundertheLaborCode,otherlaws,and
company policies. The leave is extendible when the necessity arises asspecifiedintheprotectionorder.To
applyforsuchleave(whichinpracticeiscalled"batteredwomanleave"orBWL)theemployeehastosubmita
certification from the Punong Barangay or Kagawad or prosecutor or the clerk of courtthatanactionunder
R.A. No. 9262 has been filed and is pending.
sageofthe10-dayleaveisattheoptionofthewomanemployee.Itshallcoverthedayordayswhenshewill
U
havetoattendtomedicalandlegalconcerns.Leavesnotavailedofarenon-cumulativeandnotconvertibleto
cash
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