Case Digest (A.C. No. 4838) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Duplicators, Inc. v. National Labor Relations Commission and Philippine Duplicators Employees Union-Tupas (G.R. No. 110068, February 15, 1995), the petitioner, Philippine Duplicators, Inc. (“Duplicators”), sought certiorari relief from the Third Division of the Supreme Court after the National Labor Relations Commission (“NLRC”) affirmed Labor Arbiter Felipe T. Garduque II’s order directing Duplicators to compute the 13th month pay of its salesmen on their fixed wages plus sales commissions. On November 11, 1993, the Third Division dismissed the petition, and on December 15, 1993, it denied petitioner’s motion for reconsideration with finality. On January 17, 1994, Duplicators filed a motion for leave to admit a second motion for reconsideration and the second motion itself, invoking the December 10, 1993 Second Division decision in Boie-Takeda Chemicals, Inc. v. De la Serna and Philippine Fuji Xerox Corp. v. Trajano, which had declared void the second paragraph of Case Digest (A.C. No. 4838) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On November 11, 1993, the Third Division of the Supreme Court dismissed Philippine Duplicators, Inc.’s petition for certiorari (G.R. No. 110068), affirming the NLRC’s decision and Labor Arbiter Garduque II’s order directing payment of 13th month pay computed on fixed wages plus sales commissions.
- On December 15, 1993, the Third Division denied petitioner’s first Motion for Reconsideration with finality.
- Subsequent Motions and Basis
- On January 17, 1994, petitioner filed:
- A Motion for Leave to Admit Second Motion for Reconsideration.
- A Second Motion for Reconsideration, invoking the Supreme Court Second Division’s December 10, 1993 decision in the consolidated Boie-Takeda Chemicals, Inc. and Philippine Fuji Xerox Corp. cases (G.R. Nos. 92174 & 102552), which declared null and void the second paragraph of Section 5(a) of the Revised Guidelines Implementing the 13th Month Pay.
- Petitioner argued that Boie-Takeda “directly contradicted” the Duplicators decision and sought to set aside the latter to dismiss the union’s money claims.
- En Banc Referral and Resolution
- The Third Division referred both motions to the Court en banc en consulta.
- The Court en banc accepted G.R. No. 110068 as a banc case, deliberated on the motions and the doctrines in Duplicators and Boie-Takeda, and ultimately denied both motions for lack of merit.
- Factual and Regulatory Context
- Revised Guidelines (Nov. 16, 1987) issued by Secretary Drilon:
- Section 5(a), second paragraph—“Employees who are paid a fixed or guaranteed wage plus commission are also entitled to the mandated 13th month pay, based on their total earnings during the calendar year, i.e., on both their fixed or guaranteed wage and commission.”
- In Duplicators:
- Salesmen received a small fixed salary (15–30% of total annual earnings) and the larger portion as commissions.
- A 1986 earnings table showed total earnings, 13th month pay based on fixed wages only, and fixed-wage equivalents; illustrating that commissions comprised 70–85% of total compensation.
Issues:
- Whether the Boie-Takeda decision can overturn the Duplicators decision under the doctrine of stare decisis.
- Whether the second paragraph of Section 5(a) of the Revised Guidelines is invalid or inapplicable to exclude commissions from the 13th month pay computation.
- Whether sales commissions paid by Philippine Duplicators are part of “basic salary” for purposes of computing 13th month pay.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)