Case Digest (G.R. No. L-49774)
Facts:
San Miguel Corporation (Cagayan Coca-Cola Plant) v. Hon. Amado G. Inciong, Deputy Minister of Labor, and Cagayan Coca-Cola Free Workers Union, G.R. No. L-49774, February 24, 1981, First Division, De Castro, J., writing for the Court.On January 3, 1977 the Cagayan Coca-Cola Free Workers Union (private respondent) filed a complaint against San Miguel Corporation (Cagayan Coca‑Cola Plant) (petitioner) alleging that the employer omitted from the computation of the mandatory 13th‑month pay several items: payments for sick, vacation and maternity leaves; premiums for work on rest days and special holidays; pay for regular holidays; and night differentials. Regional Office No. X issued an Order dated February 15, 1977 requiring petitioner to pay the difference between what employees should have received and what they actually received as 13th‑month pay, excluding overtime premium and emergency cost‑of‑living allowance.
Petitioner appealed to the Minister of Labor; acting for the Minister, Deputy Minister Amado G. Inciong issued an Order dated June 7, 1978 affirming the Regional Office and dismissing the appeal. Petitioner’s motion for reconsideration was denied by an Order dated December 19, 1978. Petitioner thereupon filed a petition for certiorari and prohibition (with application for preliminary injunction) in the Supreme Court to review the Deputy Minister’s December 19, 1978 Order.
On February 14, 1979 the Supreme Court issued a Temporary Restraining Order enjoining enforcement of the December 19, 1978 Order. The central question presented was whether, under Presidential Decree No. 851, payments listed above constitute “basic salary” and therefore must be included in the computation of the 13th‑month pay. The Deputy Minister and private respondent relied on prior administrative rulings taking an inclusive view; petitioner argued that PD 851 speaks only of basic salary and excludes such additional remunerations. The Court reviewed PD 851, its implementing Rules and Regulations (Section 2), and later Supplementary Rules and Regulations issued under Labor Secretary Blas Ople, and resolved the controversy in favor of petitioner....(Subscriber-Only)
Issues:
- Under Presidential Decree No. 851 and its implementing rules, are payments for sick, vacation or maternity leaves, premiums for work on rest days and special holidays, pay for regular holidays, and night differentials included in the “basic salary” used to compute...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)