Case Digest (G.R. No. 242670) Core Legal Reasoning Model
Facts:
The Insular Bank of Asia and America Employees’ Union (petitioner) filed on June 20, 1975, before the Department of Labor’s National Labor Relations Commission (NLRC), Regional Office No. IV in Manila, a complaint against the Insular Bank of Asia and America (respondent) for unpaid holiday pay under Article 208 of the Labor Code. Conciliation failed and on July 7, 1975, the case was certified for arbitration. On August 25, 1975, Labor Arbiter Ricarte T. Soriano rendered a decision ordering the bank to pay holiday wages from November 1, 1974, concluding that the bank’s use of a 303-day divisor for monthly wages excluded holiday pay. The bank did not appeal and voluntarily paid holiday pay through January 1976. Subsequently, Presidential Decree No. 850 (December 16, 1975) amended holiday pay provisions (now Article 94), and on February 16, 1976, the Department issued implementing rules (Section 2, Rule IV, Book III) presuming that monthly-paid employees earning not less than the
Case Digest (G.R. No. 242670) Expanded Legal Reasoning Model
Facts:
- Parties and Origin of Dispute
- Insular Bank of Asia and America Employees’ Union (petitioner) vs. Insular Bank of Asia and America (respondent bank); initial complaint filed June 20, 1975 before NLRC Regional Office No. IV for unpaid holiday pay.
- Case certified for arbitration July 7, 1975; Labor Arbiter Ricarte T. Soriano rendered decision August 25, 1975 granting holiday pay from November 1, 1974.
- Partial Compliance and Legislative Changes
- Respondent bank did not appeal and paid holiday pay through January 1976.
- Presidential Decree No. 850 (Dec. 16, 1975) amended Labor Code Article 94 on holiday pay.
- DOLE Implementing Rules (Feb. 16, 1976) introduced Rule IV, Book III, §2 presuming monthly‐paid employees’ holidays are paid.
- Policy Instruction No. 9 (Apr. 23, 1976) clarified that monthly employees earning ≥ P240 uniformly are presumed holiday‐paid unless deductions occur.
- Post‐Decision Proceedings
- Petitioner moved for writ of execution (Aug. 30, 1976); respondent bank opposed, citing new rules and denial of holiday pay from Feb. 1976.
- Arbiter’s order (Oct. 18, 1976) enjoined bank to continue holiday pay, invoking res judicata and finality. Bank appealed to NLRC (Nov. 17, 1976).
- NLRC en banc resolution (June 20, 1978) dismissed bank’s appeal, set aside arbiter’s injunction order, and ordered writ of execution.
- Long delays in service: petitioner served Feb. 9, 1979; bank served Feb. 13, 1979. Bank filed motion for reconsideration/appeal before Minister of Labor (Feb. 21, 1979); petitioner opposed Mar. 19, 1979.
- NLRC order (Aug. 13, 1979) directed computation of holiday pay from Apr. 1976 onward.
- Deputy Minister Inciong’s order (Nov. 10, 1979) set aside NLRC resolution of June 20, 1978 and dismissed case for lack of merit, relying on implementing rules and Policy Instruction No. 9.
Issues:
- Whether the Labor Arbiter’s decision awarding regular holiday pay, final and partially executed, could be set aside by the Deputy Minister of Labor on the basis of subsequently issued implementing rules and a policy instruction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)