G.R. No. 220828 - Republic vs. Apex Mining Co., Inc.

A petition for certiorari and mandamus was filed by the Mantrade/FMMC Division Employees and Workers Union, represented by the Philippine Social Security Labor Union (PSSLU FED. - TUCP), challenging the decision of respondent arbitrator Froilan M. Bacungan and the Mantrade Development Corporation.
The dispute arose from the arbitrator’s ruling denying holiday pay to monthly paid employees, as provided under Article 94 of the Labor Code, on the ground that such employees are presumed to be paid for all calendar days under the implementing rules.

The arbitrator based his decision on Section 2, Rule IV, Book III of the Rules and Regulations implementing Article 94 of the Labor Code, which provides that employees uniformly paid by the month, regardless of the actual number of working days, are deemed to have been paid for all days in the month.
The petitioner questioned the constitutionality and validity of this interpretation and the pertinent regulatory provision, arguing that monthly paid employees are not excluded from the benefits of holiday pay as provided by the Labor Code.

It argued that the petitioner was barred by Article 263 of the Labor Code which renders voluntary arbitration awards as final, inappealable, and executory.
It further relied on the stipulations of the Collective Bargaining Agreement and Article 2044 of the Civil Code, which validate the finality of the arbitrator’s award.

The petition erroneously sought judicial review of an error in judgment rather than jurisdiction.
The special civil action of certiorari was inappropriate because the respondent arbitrator was not an “officer exercising judicial functions” under Rule 65, Section 1 of the Rules of Court.
The remedy of appeal by certiorari under Section 29 of the Arbitration Law did not apply since labor disputes arbitration is expressly excluded by the law.

The Court referenced its earlier decision in Oceanic Bic Division (FFW) vs. Romero, emphasizing that judicial review may be exercised over voluntary arbitration decisions when errors of law or abuse of discretion occur.
The case of Insular Bank of Asia and America Employees’ Union vs. Inciong (Oct. 24, 1984) was cited for its holding that the administrative rules excluding monthly paid employees from holiday pay were null and void due to their effect of de facto amending the Labor Code provisions.
The ruling in Chartered Bank Employees Association vs. Ople (Aug. 28, 1985) reiterated that the additional exclusion for monthly paid employees was a deprivation not supported by law and, therefore, ultra vires.
Additional precedents such as CBTC Employees Union vs. Clave and decisions on the appropriateness of mandamus as a remedy were also discussed to frame the legal context of the dispute.

Whether the decision of the voluntary arbitrator, being final under Article 263 of the Labor Code and the applicable arbitration rules, is subject to judicial review for errors in law and abuse of discretion.
Whether the petitioner's remedy for certiorari and mandamus is proper given that the respondent arbitrator's decision was allegedly an error of judgment and a misinterpretation of statutory law.

Whether Section 2, Rule IV, Book III of the Rules and Regulations implementing Article 94 of the Labor Code is valid.
Whether the administrative interpretation that monthly paid employees are deemed to have received holiday pay (irrespective of the number of working days) is in conformity with the Labor Code and its amendments.

Whether the administrative rules have, in effect, amended the substantive provisions of Article 94 by excluding monthly paid employees from the benefits of holiday pay.
Whether such an exclusion constitutes a lawful delegation of interpretative authority or amounts to an unconstitutional deprivation of benefits.

Whether mandamus is applicable to compel respondent corporation to perform its legal duty to grant holiday pay, given that such a duty is clearly established by subsequent decisions and statutory interpretation.