Friday, December 21, 2012

IBAAEU v. Inciong


G.R. No. L-52415 October 23, 1984, Makasiar, J.

(Labor Standards: Proper Construction and Interpretation of Labor Laws)

FACTS

The Secretary of Labor, issued Policy no. 9 interpreting article 94 of Labor Code as regards Right to Holiday pay, stated among others, that PD 850 principally intended to benefit daily-paid workers. Those who are paid by the month, i.e., he is paid uniformly from January to December is presumed to have been paid with legal holidays, unless his salary is deducted for the month the holiday occurs. Invoking this Policy, the Bank stopped paying its employees for the legal holidays.

ISSUE

Whether or not, PD 850 was intended only for daily wage workers.

RULING

It is elementary in the rules of statutory construction that when the language of the law is clear and unequivocal the law must be taken to mean exactly what it says. In the case at bar, the provisions of the Labor Code on the entitlement to the benefits of holiday pay are clear and explicit - it provides for both the coverage of and exclusion from the benefits. In Policy Instruction No. 9, the then Secretary of Labor went as far as to categorically state that the benefit is principally intended for daily paid employees, when the law clearly states that every worker shall be paid their regular holiday pay. This is a flagrant violation of the mandatory directive of Article 4 of the Labor Code, which states that "All doubts in the implementation and interpretation of the provisions of this Code, including its implementing rules and regulations, shall be resolved in favor of labor." Moreover, it shall always be presumed that the legislature intended to enact a valid and permanent statute which would have the most beneficial effect that its language permits (Orlosky vs. Haskell, 155 A. 112.)

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