NAPOLEON R. REFUGIDO, ALEX PURAL, JOEY AGUIRRE, BERNIE J. LLORENTE, JOEL A. DADIZON AND MEL T. MAGALLANES, PETITIONERS, VS. NATIONAL LABOR RELATIONS COMMISSION, METRO PSYCHIATRY…

Refugido versus National Labor Relations Commission

The Case

This is a labor case in which a group of employees, led by Napoleon Refugido, sought relief against their employer, Metro Psychiatry, and against the National Labor Relations Commission. The employees claimed that they were paid less than what the law required and that they were denied the benefits that should have accompanied their work. The case matters because it shows how the labor tribunals compute and enforce monetary awards for underpaid workers, and how the Supreme Court treats findings of fact that have been affirmed on reconsideration below.

Procedural History

The employees filed a petition before the labor tribunal, and on the first of September 2014, a Decision was promulgated granting the petition. The employer, dissatisfied, filed a Motion for Reconsideration of that Decision. The labor tribunal found no convincing and justifiable reason to modify, alter, or reverse its earlier ruling, and it denied the motion. The matter then reached the Supreme Court through a petition for review, where the employees appear as petitioners and the National Labor Relations Commission and Metro Psychiatry appear as respondents.

Facts

The employees, among them Refugido, Pural, Aguirre, Llorente, Dadizon, and Magallanes, worked for Metro Psychiatry. They received wages and benefits that fell short of what the law required, and the shortfall was reflected in the monthly summaries of their wages and benefits that the employer itself submitted.

Because of this, the employees brought a petition claiming their salary differentials and the benefits that should have accompanied their employment, including overtime pay, night differential, holiday pay, and thirteenth month pay.

The labor tribunal agreed with the employees and issued a Decision on the first of September 2014 granting the petition and ordering the employer to pay the amounts due. The employer moved for reconsideration, but the tribunal stood its ground and denied the motion, holding that the arguments raised had already been passed upon.

Issues

• Whether or not the employees are entitled to double their salary differentials.
• Whether or not the employees are entitled to the difference in their benefits in terms of overtime pay, night differential, holiday pay, and thirteenth month pay.
• Whether or not the employer is liable for attorney's fees equivalent to ten percent of the total monetary award.
• Whether or not interest at the rate of six percent per annum should be imposed on all monetary awards from the date of finality of the Decision until full payment.

Applicable Provisions

The Decision's dispositive portion, which the Court set out and affirmed, provides:

WHEREFORE, premises considered, the instant petition is hereby GRANTED. Private respondent is hereby ORDERED to pay double the salary differentials of petitioners, the difference of their benefits in terms of overtime pay, night differential, holiday pay and 13th month pay, the last to refer only to petitioner Aguirre. Private respondent is also ORDERED to pay ten percent (10%) of the total monetary award as attorney's fees. Interest at the rate of six percent (6%) per annum shall be imposed on all monetary awards from date of finality of this Decision until full payment. The Labor Arbiter concerned shall make the necessary computation on the basis of the entries in the monthly summaries of petitioners' wages and benefits submitted by private respondent. SO ORDERED.

This is the award that the Court sustained, and it fixes both the amounts owed and the rate of interest that runs on them.

Ruling

On the first issue, the Court upheld the award of double the salary differentials, because the employer's own monthly summaries showed the wages actually paid and the shortfall against what was due.

On the second issue, the Court likewise upheld the award of the difference in benefits, namely overtime pay, night differential, holiday pay, and thirteenth month pay, with the thirteenth month pay referring only to petitioner Aguirre.

On the third issue, the Court sustained the award of attorney's fees equivalent to ten percent of the total monetary award.

On the fourth issue, the Court affirmed that interest at the rate of six percent per annum shall be imposed on all monetary awards from the date of finality of the Decision until full payment.

The Court also directed that the Labor Arbiter concerned make the necessary computation on the basis of the entries in the monthly summaries of the employees' wages and benefits submitted by the employer. In denying the motion for reconsideration, the tribunal explained that no convincing and justifiable reason was advanced that would justify modifying, altering, or reversing the questioned Decision, and that the allegations and arguments had already been amply discussed and passed upon.

Doctrine

First, an employee who is paid less than what is due is entitled to the salary differential, and where the law so provides, the differential may be doubled.

Second, the benefits that accompany employment, namely overtime pay, night differential, holiday pay, and thirteenth month pay, must be paid in full, and any difference must be made up by the employer.

Third, attorney's fees equivalent to ten percent of the total monetary award may be imposed in favor of the employees.

Fourth, interest at the rate of six percent per annum runs on all monetary awards from the date of finality of the Decision until full payment.

Fifth, the computation of the award may be left to the Labor Arbiter, who shall base it on the entries in the monthly summaries of wages and benefits submitted by the employer.

Disposition

The Court upheld the labor tribunal's Decision granting the petition, and the employer was ordered to pay the salary differentials, the difference in benefits, attorney's fees, and interest, with the Labor Arbiter to compute the amounts.

Remember This

The single line worth memorizing is that the employer's own monthly summaries of wages and benefits are the basis for computing the monetary award, and interest at six percent per annum runs from finality until full payment. Examiners like to use this case on the computation of labor awards, the grant of attorney's fees, and the imposition of interest on monetary judgments.