G.R. No. 172161 - SLL International Cables Specialist vs. National Labor Relations Commission

Petitioner-Appellant: Automotive Parts & Equipment Company, Incorporated, duly incorporated on January 5, 1961, and engaged in business where its employees are paid both on a daily and monthly basis.
Respondents-Appellees:

The original Minimum Wage Law (Republic Act No. 602, 1951) established a wage floor for laborers and contained Section 19, which prohibits employers from reducing any wage previously paid in excess of the minimum wage or the supplements granted on the date of enactment.
The Amendatory Act (Republic Act No. 4180), which took effect on April 21, 1965, amended certain provisions of RA 602 by increasing the minimum daily wage to six pesos (P6.00), thereby imposing a two-peso (P2.00) increase over the previous rate.
The amendment expressly provided for a six-peso daily wage for industrial establishments, whether employees are paid on a daily or monthly basis, as well as incorporating mechanisms to prevent employers from evading the legislative mandate.

The petitioner sought declaratory relief to construe Section 19 of RA 602 in such a manner as to permit it to reduce its liability on monthly-paid employees from a minimum monthly wage of P180.00 to P152.00.
Its proposed scheme involved paying employees at the rate of the minimum daily wage (P6.00) for six days a week (Monday to Saturday).
The petitioner argued that the prohibition on reducing wages or supplements in Section 19 of RA 602 should apply only to employers in existence at the time of the Act’s enactment and not prospectively to those established later.

The lower court rejected the petitioner’s interpretation and found it inconsistent with the clear statutory language and the constitutional mandate to protect labor through ensuring a decent minimum wage.
The decision of the lower court, issued on March 30, 1966, was ultimately appealed by the petitioner.

The petitioner relied on a literal reading of Section 19 of RA 602, emphasizing the phrases “wage now paid” and “supplements furnished on the date of enactment,” contending that these should limit the application of the prohibition to pre-existing wage practices.
It argued that the subsequent Amendatory Act (RA 4180), which did not expressly repeal Section 19, should not be construed to expand the scope of the wage protection provision to include its own legislative scheme.
The petitioner further maintained that the interpretative bulletin of the Bureau of Labor Standards mandating all monthly-paid employees receive a minimum wage of P180.00 was an overreach beyond the text of the statute.

The Constitution’s Directive: The promotion of social justice and the protection of labor, as enshrined in Art. II, Sec. 5 and Art. XIV, Sec. 6.
Statutory Provisions:

RA 602, Section 19, which prohibits any reduction of wages previously paid above the new minimum wage or the supplements granted at the time of the Act’s enactment.
RA 4180, with Section 2 stating that any previously enacted law inconsistent with its provisions is repealed, while noting that Section 19 of RA 602 is not inconsistent and is deemed reenacted.

Civil Code Provision: Article 1702, mandating that all labor legislation and labor contracts be construed in favor of the safety and a decent living for the laborer.

The court noted the petitioner’s attempt to use a seemingly technical interpretation of the statutory language to circumvent a clear legislative mandate.
It underscored the importance of adhering to the explicit purpose of the law—to secure a decent living for laborers by ensuring a proper minimum wage, thereby giving concrete effect to the constitutional directive on social justice.
The lower court’s decision was firmly grounded on these statutory and constitutional bases, leading to the affirmation of its ruling on appeal.

Whether Section 19 of Republic Act No. 602, as implicitly reenacted by Republic Act No. 4180, prohibits the petitioner from reducing the wages of its monthly-paid employees from P180.00 to P152.00.
Whether the petitioner’s interpretation of the phrase “wage now paid” in Section 19, which seeks to limit the application of wage protection to employers established before the Act’s effective date, is tenable under the statutory language and the constitutional mandate of promoting social justice.
Whether the attempt by the petitioner to evade the legislatively decreed increase in the minimum wage—thereby potentially compromising the safety and decent living of its employees—is legally permissible.