Case Digest (G.R. No. 78909) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Maternity Children’s Hospital, represented by Antera L. Dorado as holdover President, the petitioner—a semi-government hospital in Cagayan de Oro subsidized by the Philippine Charity Sweepstakes Office and the city government—employed forty-one workers who received salaries, living allowances, and food deductions. On May 23, 1986, ten employees filed ROX Case No. CW-7I-86 with the Regional Director of Labor and Employment, Region X, alleging underpayment of statutory minimum wages and Emergency Cost of Living Allowances (ECOLAs). Following inspection of payrolls from May 1974 to May 1986, two Labor Standards and Welfare Officers reported underpayments totaling ₱654,756.01 to thirty-six employees. On August 4, 1986, the Regional Director ordered payment of ₱723,888.58 and compliance with prevailing wage standards within ten days. Petitioner appealed to the Secretary of Labor, Hon. Augusto S. Sanchez, who on September 24, 1986 modified the computation period to May 23, 1983–May Case Digest (G.R. No. 78909) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Maternity Children’s Hospital, a semi-government institution managed by the Cagayan de Oro Women’s Club under holdover President Antera L. Dorado; finances derived from club funds, paying patients (avg. 130/mo.), Philippine Charity Sweepstakes Office, and Cagayan de Oro City; employs 41 staff, provides salary, ECOLA, and food (food costs deducted).
- Respondents: Hon. Secretary of Labor and the Regional Director of Labor, Region X.
- Procedural History
- May 23, 1986 – Ten employees filed ROX Case No. CW-71-86 with the Regional Director alleging underpayment of wages and ECOLAs.
- June 16, 1986 – Regional Director ordered inspection; LSWOs obtained payrolls (May 1974; Jan, Nov 1985; May 1986).
- July 17, 1986 – Inspection report confirmed underpayment of ₱654,756.01 covering 36 employees and recommended payment.
- August 4, 1986 – Regional Director’s Order required petitioner to pay ₱723,888.58 and comply with prevailing wage laws.
- September 24, 1986 – Secretary of Labor modified computation period to May 23, 1983–May 23, 1986, and remanded for recomputation.
- May 13, 1987 – Secretary denied motion for reconsideration.
- Petition for certiorari filed in the Supreme Court challenging jurisdiction, coverage of award, and adequacy of reasoning.
Issues:
- Jurisdiction
- Whether the Regional Director, under Article 128(b) as amended by EO 111 (and earlier PD 850 and MOLE Policy Instructions Nos. 6, 7, 37), had authority to adjudicate money claims for salary differentials and ECOLAs.
- Extent of Coverage and Adequacy
- Whether the award could extend to (a) non-signatory employees still in service at filing, and (b) employees who had already separated before the complaint.
- Whether the Regional Director’s and Secretary’s orders “state clearly and distinctly the facts and the law” on which the awards were based.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)