Case Digest (G.R. No. L-64967)
Facts:
Engineering Equipment, Inc. v. Minister of Labor, Director of Employment Services and Miguel V. Aspera, G.R. No. 64967, September 23, 1985, Supreme Court Second Division, Aquino, J., writing for the Court.Miguel V. Aspera worked for Engineering Equipment, Inc. in Saudi Arabia from April 26, 1977 to April 16, 1978 under a written contract providing a six-day work week with a ten-hour workday and a monthly salary of P750 (noted also as P860). The contract expressly stated that the employer might require overtime beyond ten hours, and that the salary was "P750.00 plus overtime pay for work rendered during restdays/holidays and/or in excess of ten (10) hours during regular working days." Aspera actually worked ten hours daily for 335 working days and later claimed that his salary should have been computed on an eight-hour day basis, seeking overtime compensation for the additional two hours per day (670 hours) amounting to $814.85.
The Director of Employment Services and the National Labor Relations Commission (NLRC) sustained Aspera’s claim and awarded him the overtime pay, declaring the stipulation for a ten-hour working day void under the Labor Code's Eight-Hour Labor Law—specifically Sec. 83 (normal hours not to exceed eight hours a day) and Sec. 87 (work beyond eight hours treated as overtime).
The employer petitioned to overturn those rulings. It asserted that Aspera was a managerial employee exempt from overtime under Sec. 82 of the Labor Code; that several employees had similar written contracts with "built‑in" overtime reflected in adjusted basic pay; and that the contracts had been submitted to and approved by BES Director Jonathan M.R.A. de la Cruz, whose prior approval meant the employer acted in good faith in enforcing the contract. The petitioner also noted Asp...(Pro-only)
Issues:
- Did the Acting Minister of Labor and the Director of Employment Services commit grave abuse of discretion amounting to lack of jurisdiction in awarding overtime pay?
- Was the contractual stipulation of a ten-hour workday void under the Labor Code such that Miguel V. Aspera was entitled to overtime pay?
- Was Aspera exempt from overtime pay as a managerial employee under Sec. 82 of the Labor Code, and did the prior approval by the BES Director and the employer’s good-faith ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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