G.R. No. L-57078. February 20, 1984 (Case Brief / Digest)

### Title: **Dela Concepcion et al. v. Mindanao Portland Cement Corporation**

### Facts:

– **January 4, 1974:** The President of the Philippines issued an appeal to private sector employers to augment the earnings of low-income workers due to rising prices of commodities.

– **PD No. 390:** The President issued a decree granting emergency allowances to government employees.

– **PD No. 525 & LOI 174:** These laws were implemented to provide an emergency living allowance of P50 per month to low-wage earners in the private sector.

– **February-May, 1974:** Mindanao Portland Cement Corporation complied with the emergency living allowance mandate but only for three months. Subsequently, the allowance was canceled by Office Order No. 74-74, designated as “Salary Adjustment of Plant Employees.”

– **Complaint by Workers:** Petitioners (Dela Concepcion and 164 other employees) filed a complaint for non-payment of the emergency living allowance mandated by PD 525 and LOI 174.

– **December 23, 1976:** The Executive Labor Arbiter dismissed the complaint, stating that the allowance was incorporated into the employees’ basic salary.

– **Appeal to NLRC (Case No. 215-76):** The National Labor Relations Commission affirmed the Arbiter’s decision.

– **March 10, 1978:** The Minister of Labor upheld the NLRC’s decision.

– **Petition for Certiorari:** Petitioners filed a petition for certiorari to the Supreme Court.

### Issues:

1. **Whether the Salary Adjustment constitutes compliance with PD No. 525 and LOI 174.**
2. **Whether the increases given were in substantial compliance with the emergency living allowance mandated by law.**

### Court’s Decision:

– **Burden of Proof:** The Supreme Court emphasized that the burden of proof was on the corporation to show that the emergency living allowance had been appropriately incorporated into the basic salary. The corporation failed to do so.

– **Compliance Analysis:** The Court scrutinized whether the salary increases ranging from P0.25 per day to P50 per month matched the mandated P50 monthly allowance. It found no substantial compliance.

– **Dual Purpose of Office Order No. 74-74:** The Court acknowledged that the company claimed a dual purpose for the order—incorporating allowances into basic pay and providing merit increases. However, it found this claim unsubstantiated by evidence.

– **Protection of Workers:** Upholding the constitutional mandate to protect labor, the Court sided with the petitioners, stating that the low-income workers should be given more legal protection.

– **Conclusion:** The resolution by the Minister of Labor and the decision of the NLRC were set aside. The employer was directed to pay the petitioners the mandated allowances under LOI No. 174.

### Doctrine:

– **Protection to Labor:** The court reiterated the constitutional mandate of protection to labor, emphasizing that employers should not circumvent protective statutes meant for low-income workers.

– **Burden of Proof:** The principle that when employers assert compliance with legal mandates affecting employees, the burden is on the employer to provide clear evidence of such compliance.

### Class Notes:

– **Emergency Living Allowance:** Essential provisions under PD 525 and LOI 174 mandating P50 per month.
– **Burden of Proof:** Employers must prove compliance with statutory benefits.
– **Protection to Labor:** Constitutional provision emphasizing enhanced legal protection for low-income workers.

Relevant legal statutes applied:
– **PD No. 525:** Mandates an emergency living allowance.
– **LOI 174:** Provides implementation guidelines for emergency living allowances.

### Historical Background:

– **Economic Context:** The early 1970s saw significant economic challenges, including rising prices of commodities, prompting governmental measures to support low-income workers.
– **Legal Reforms:** PD No. 525 and LOI 174 were part of broader labor reforms aimed at stabilizing workers’ living standards amid economic volatility.

This case underscores the judiciary’s role in ensuring legislative mandates aimed at protecting labor are faithfully implemented by employers.


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