Case Digest (G.R. No. 150326)
Facts:
The National Wages and Productivity Commission (NWPC) and the Regional Tripartite Wages and Productivity Board (RTWPB)-NCR v. The Alliance of Progressive Labor (APL) and the Tunay na Nagkakaisang Manggagawa sa Royal (TNMR-APL), G.R. No. 150326, March 12, 2014, First Division, Bersamin, J., writing for the Court.This case arose from the issuance of Wage Order No. NCR-07 (effective October 14, 1999) by the RTWPB–NCR, which increased daily minimum wages in the National Capital Region and pegged the minimum at P223.50/day, but excluded or made exemptible certain sectors through Section 2(A) and Section 9(2) of the wage order. The exclusions involved sectors previously granted different increases under Wage Order No. NCR-06 (agriculture, cottage/handicrafts, private hospitals ≤100 beds, and small retail/service establishments) and an exemption for exporters meeting specified export-sales and contract conditions.
The exclusions prompted workers’ groups—the Alliance of Progressive Labor (APL) and the Tunay na Nagkakaisang Manggagawa sa Royal (TNMR)—to appeal to the NWPC (docketed W.O.-99-001), arguing that neither the NWPC nor the RTWPB had authority to expand non-coverage or create the challenged exemptible categories and that those provisions should be voided.
On February 28, 2000, the NWPC denied the appeal and upheld Sections 2(A) and 9(2). The NWPC found that: (1) Article 122(e) of the Labor Code, as amended by Republic Act No. 6727, vested the RTWPBs with wage-fixing functions and authority to receive and act on exemption applications subject to NWPC guidelines; (2) the NWPC’s own instruments—NWPC Guidelines No. 001-95 (Revised Rules of Procedure on Minimum Wage Fixing) and NWPC Guidelines No. 01, Series of 1996—recognized and regulated exemptions; and (3) the RTWPB–NCR had substantial, justifiable reasons (public hearings, socioeconomic data, consultations) for the exclusions given lingering economic difficulties after the Asian financial turmoil. The NWPC also denied TNMR’s motion for reconsideration on July 17, 2000.
APL and TNMR brought certiorari to the Court of Appeals (CA) asserting grave abuse of discretion by the NWPC in upholding the exemptions and contending that the RTWPB lacked authority to add exemptible categories beyond those enumerated by NWPC guidelines. On June 15, 2001, the CA granted the petition, set aside the NWPC decisions, and declared Sections 2(A) and 9(2) of Wage Order No. NCR-07 null and void on the ground that the NWPC’s and RTWPB’s powers did not include granting additional exemptions and because the NWPC had not approved those sections. The CA denied reconsideration on September 11, 2001.
The NWPC and RTWPB–NCR filed a petition for review on certiorari before the Supreme Court under Rule 45, challenging the CA’s ruling. The Supreme Court First Division heard the case and rendered the decision of March 12, 2014 (ponente: Bersamin, J.). The petitions raised, in essence,...(Pro-only)
Issues:
- Whether the RTWPB–NCR had authority to provide additional exemptions in Wage Order No. NCR-07 under Section 3 of Republic Act No. 6727 and the NWPC guidelines.
- Whether the NWPC complied with the review/approval requirement of NWPC Guidelines No. 01, Series of 1996 when it upheld Sections 2(A) and 9(2) of Wage Order No. NCR-07 in its February...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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