Case Summary (G.R. No. 146775)
Factual Background
On October 17, 1992, DOLE conducted a standard inspection of SMC and determined there was underpayment of Muslim holiday pay to its employees. The inspection results were communicated to SMC, which contested the findings. Subsequent summary hearings took place on November 19, 1992, May 28, 1993, and October 4-5, 1993; nonetheless, SMC did not present sufficient evidence demonstrating compliance with holiday pay regulations. Consequently, on December 17, 1993, Director Macaraya issued a compliance order directing SMC to recognize Muslim holidays as regular holidays and ensure holiday pay was disbursed within thirty days.
Procedural History
SMC appealed the compliance order to the DOLE main office in Manila; however, initially, the appeal was dismissed due to late filing. Although this dismissal was reconsidered in July 1998 after determining that the appeal was timely, it was subsequently dismissed again due to a lack of merit, affirming Macaraya's compliance order. Following this, SMC sought relief from the Supreme Court through a petition for certiorari, which was subsequently referred to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals, in its decision promulgated on May 8, 2000, modified the previous order regarding Muslim holiday pay, reducing the payment due from 200% to 150% of an employee's basic salary, and mandated remanding the case to the Regional Director for accurate computation. Following the denial of SMC's motion for reconsideration, the petition for certiorari was filed at the Supreme Court, wherein SMC claimed that the public respondents had erred and acted with grave abuse of discretion.
Legal Framework
Applicable laws in this case include Presidential Decree No. 1083, also known as the Code of Muslim Personal Laws, which recognizes official Muslim holidays and stipulates their observance in specified regions. Additionally, Article 94 of the Labor Code provides workers the right to holiday pay during legal holidays. These legal provisions establish a framework for determining entitlement to holiday pay, irrespective of the employee's religion.
Issue of Jurisdiction and Due Process
SMC contended that the compliance order issued by Regional Director Macaraya exhibited grave abuse of discretion due to a claimed lack of due process. The Court found that SMC was sufficiently informed of the compliance order and participated in hearings, thereby diminishing the claim of the denial of due process. Furthermore, the Court confirmed that Macaraya acted within his jurisdiction as a duly authorized representative of the Secretary of Labor under the Labor Code.
Non-Discrimination on Basis of Religion
The Court categorized SMC's claims regarding the exclusivity of holiday pay for Muslims under Article 3(3) of Presidential Decree No. 1083 as misinterpretations, emphasizing that benefits should not be limited by religious affiliation. The conclusion reached by Undersecretary Espaol—that allowances for holiday pay should
...continue readingCase Syllabus (G.R. No. 146775)
Case Background
- The case arose from a petition filed by San Miguel Corporation (SMC) against the decision and resolution of the Court of Appeals related to the payment of Muslim holiday pay to employees.
- The Department of Labor and Employment (DOLE) conducted an inspection on 17 October 1992 at SMC's facility in Iligan City, revealing underpayment of regular Muslim holiday pay to employees.
- DOLE communicated the inspection results to SMC, which were received and explained to personnel officer Elena dela Puerta.
Compliance Orders and Appeals
- SMC contested DOLE's findings, leading to summary hearings held on 19 November 1992, 28 May 1993, and 4-5 October 1993.
- SMC failed to present evidence proving compliance with the holiday pay requirements, prompting DOLE Director IV Allan M. Macaraya to issue a compliance order on 17 December 1993.
- SMC appealed the compliance order, but its appeal was initially dismissed for late filing. This dismissal was later reconsidered but was ultimately denied for lack of merit.
Court of Appeals Decision
- The Court of Appeals, in its decision dated 08 May 2000, modified the earlier order, adjusting the payment for Muslim holiday pay from 200% to 150% of the employee's basic salary and remanding the case for computation of the holiday pay.
- SMC's motion for reconsideration was denied, leading to a further appeal to the Supreme Court.