Title
Atok-Big Wedge Mutual Benefit Association vs. Atok-Big Wedge Mining Co., Inc.
Case
G.R. No. L-7349
Decision Date
Jul 19, 1955
A labor union and mining company disputed wage increases and deductions for facilities, leading to a Supreme Court ruling affirming a compromise agreement and clarifying minimum wage compliance and additional compensation for holiday work.
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Case Digest (G.R. No. L-7349)

Facts:

  1. Labor Union Demands: On September 4, 1950, the Atok-Big Wedge Mutual Benefit Association (petitioner labor union) submitted several demands to the Atok-Big Wedge Mining Company, Inc. (respondent), including a P0.50 daily wage increase.
  2. Court of Industrial Relations (CIR) Involvement: The matter was referred to the CIR for arbitration (Case No. 523-V). Some demands were granted, while others, including the wage increase, were rejected.
  3. CIR Decision (July 14, 1951): The CIR fixed the minimum wage at P2.65/day with rice ration or P3.20/day without rice ration. It denied deductions for housing facilities and efficiency bonuses and made the award retroactive to September 4, 1950.
  4. Company’s Appeal: The mining company appealed the decision to the Supreme Court (G.R. No. L-5276).
  5. Company’s Financial Struggles: On October 15, 1952, the company filed an urgent petition to stop operations and lay off employees due to heavy losses, increased taxes, and the enforcement of the Minimum Wage Law.
  6. Compromise Agreement (October 29, 1952): To avoid closure, the parties reached an agreement effective from August 4, 1952, to December 31, 1954. The agreement included:
    • Compliance with the Supreme Court’s decision in G.R. No. L-5276.
    • Valuation of facilities (e.g., rice ration, housing, medical treatment) as part of wages, totaling P1.80/day.
    • Payment of a minimum wage of P4/day, with deductions for facilities.
  7. Supreme Court Decision (March 3, 1953): The Court affirmed the CIR’s decision, fixing the minimum wage at P3.20 without rice ration or P2.65 with rice ration.
  8. Labor Union’s Petition (June 13, 1953): The union sought enforcement of the agreement as modified by the Supreme Court decision and the Minimum Wage Law, demanding P3.45/day with rice ration or P4/day without rice ration, plus differential pay from August 4, 1952.
  9. CIR’s Denial (September 22, 1953): The CIR denied the union’s petition, ruling that the October 29, 1952, agreement superseded the Supreme Court decision and the Minimum Wage Law.
  10. Additional Compensation Issue: The union also claimed that the company should pay 50% additional compensation for Sunday and holiday work based on the P4 minimum wage, not the P2.20 cash portion.

Issue:

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Ruling:

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Ratio:

  1. Binding Nature of Agreements: Parties to a labor dispute may enter into binding agreements, even if they modify or supersede prior court decisions, provided such agreements are fair, reasonable, and comply with the law.
  2. Deductions for Facilities: Under the Minimum Wage Law, facilities customarily furnished by the employer (e.g., housing, rice ration) may be deducted from the minimum wage, provided their value is fair and reasonable.
  3. Additional Compensation for Sunday and Holiday Work: The law requires a minimum of 25% additional compensation based on the laborer’s regular remuneration. Payments exceeding this minimum are lawful.
  4. Harmonization of Agreements and Laws: Agreements between labor unions and employers must be interpreted in light of applicable laws, ensuring that neither party is unjustly disadvantaged.


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