Case Digest (G.R. No. 204651) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Our Haus Realty Development Corporation v. Parian et al., decided on August 6, 2014 under G.R. No. 204651, the petitioning employer, Our Haus Realty Development Corporation, is engaged in construction business and hired respondents Alexander Parian, Jay Erinco, Alexander Canlas, Jerry Sabulao, and Bernardo Tenedero as laborers from 1999 to 2005. From 2007 to 2010, respondents’ daily wages ranged from ₱312.00 to ₱383.50, allegedly below the minimum wage rates prescribed in Wage Orders No. NCR-13 (₱362.00) and No. NCR-14 (₱382.00). In May 2010, Our Haus suspended projects due to financial distress, placed affected workers on vacation leave, and later recalled them. Instead of returning, the respondents filed before the Labor Arbiter (LA) a complaint for underpayment of wages and nonpayment of holiday pay, service incentive leave (SIL), 13th month pay, and overtime. The LA ruled for the employer, counting the fair value of meals and lodging under Article 97(f) of the Labor Code Case Digest (G.R. No. 204651) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Employment
- Petitioner Our Haus Realty Development Corporation is engaged in the construction business.
- Respondents Alexander Parian, Jay Erinco, Alexander Canlas, Jerry Sabulao, and Bernardo Tenedero are laborers hired between 1994 and 2005, with daily wage rates ranging from ₱312.00 to ₱383.50 (2007–2010).
- Wage Dispute and Claims
- In May 2010, petitioner suspended projects due to financial distress; respondents were asked to take vacation leaves.
- Respondents filed before the Labor Arbiter (LA) a complaint for underpayment of wages (below NCR-13/362.00 and NCR-14/382.00 wage orders), and nonpayment of holiday pay, service incentive leave (SIL), 13th-month pay, and overtime.
- Procedural History
- LA ruled for petitioner, counting the fair value of board (3 meals/day) and lodging against the minimum wage per Art. 97(f) and DOLE Mem. Circ. No. 2, and denied other claims for lack of proof.
- NLRC reversed LA: excluded board and lodging (no written authorization per Mayon Hotel v. Adana), awarded pro rata 13th-month and SIL pays, denied overtime for lack of proof.
- CA affirmed NLRC: no distinction between “deduction” and “charging,” petitioner failed to meet requirements in Mabeza v. NLRC; upheld SIL and attorney’s fees awards.
- Supreme Court denies Rule 45 petition, affirming CA’s May 7, 2012 decision and November 27, 2012 resolution.
Issues:
- Deductibility of Board and Lodging
- Is there a meaningful distinction between “deducting” and “charging” the value of facilities for minimum-wage compliance?
- Can petitioner credit board and lodging without proving customary furnishing, obtaining written consent, and establishing fair value?
- Entitlement to Other Benefits
- Are respondents entitled to pro rata 13th-month pay, SIL, holiday pay, and overtime?
- Does omission of SIL claim in the pro forma complaint bar its grant?
- Attorney’s Fees
- Can respondents, represented by the Public Attorney’s Office (PAO), recover attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)