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Bisig ng Manggagawa sa PRC v PRC bonus and other fringe benefits.

bonus and other fringe benefits. The Court observed that in framing up their CBA
September 30, 1981| Abad Santos, J.| Labor Relations specially on the provision regarding overtime pay, it was only the regular base pay
Digester: Melliza, Frente Sur L. that was considered, and the same fact was undeniably known to the petitioner -
the very reason, according to the court, why it attempted to have a different
SUMMARY: Bisig filed a petition for declaratory relief seeking that their Christmas provision pertaining to overtime pay which would include Christmas bonus and
bonus be included as part of their basic pay for the computation of overtime pay. Bisig other benefits. This factual information by itself constrains the petitioner to
cites NAWASA vs. NAWASA Consolidated Unions where it was declared that the question the intention of that particular phrase in their CBA pertaining to overtime
'regular rate' is also deemed to include other incentives and bonuses which employers pay but could only claim that it violated the Nawasa doctrine and insist that it be
may receive as part of their regular pay. On the other hand, PRC argued that, per the reformed to conform to said doctrine.
CBA, it was never intended to include the employees' Christmas bonus in the  The Supreme Court held that the Nawasa ruling did not limit that the computation
computation of the overtime pay. Court ruled for PRC. Court said that, per the CBA’s of overtime pay to be based solely on the employees' regular wage or salary, which
provision regarding overtime pay, it was only the regular base pay that was considered according to law includes bonuses and other benefits. What is important is that the
to compute the overtime pay. Further, what is important in the Nawasa ruling is that the product resulting from the computation must always be equal or higher than the
the product resulting from the computation must always be equal or higher than the statutory requirement of 25% more than the regular wage. In the case at bar, the
statutory requirement of 25% more than the regular wage. Here, the Nawasa ruling was formula adopted by the CBA is 50% more than the regular base pay, which when
not violated, since the formula adopted by the CBA is 50% more than the regular base computer is much higher than what can be arrived at using the statutory formula.
pay, which when computed is much higher than what can be arrived at using the Thus, the Court declared that the provisions of the CBA as to the computation of
statutory formula. overtime pay has amply complied with what is required by law, and therefore is
valid and not in contravention to the Nawasa doctrine.
DOCTRINE: "Regular base pay" means regular basic pay which necessarily
EXCLUDES money received in different concepts such as Christmas bonus and other
fringe benefits.
FACTS:
 In 1966, petitioner union Bisig ng Manggagawa ng Philippine Refining Company,
Inc. filed with the Court of First Instance of Manila a petition for declaratory relief
seeking, among others, the judgement that their Christmas bonus be included as
part of their basic pay for the computation of overtime pay.
 Petitioner based its contention primarily on the ruling of the Supreme Court in
NAWASA vs. NAWASA Consolidated Unions, et all G.R. No. L-18938, August
31, 1964, 11 SCRA 766 where it was declared that the 'regular rate' is also deemed
to include other incentives and bonuses which employers may receive as part of
their regular pay.
 Respondent Philippine Refining Company, Inc. on the other hand contended that
in their collective bargaining agreement (CBA), the parties never intended to
include the employees' Christmas bonus in the computation of the overtime pay,
and that it did agree to raise the overtime rate to 50% instead of 25% of the regular
base pay precisely on the consideration that it be based only on the regular base pay
and should not include Christmas bonus.

RULING: PETITION DISMISSED, the decision appealed from is affirmed.

WON in the interpretation of the CBA re overtime pay, the term “regular base
pay” should include Christmas bonus.—No.
 The Supreme Court ruled that the term "regular base pay" is clear, unequivocal and
requires no interpretation. It held that the term means regular basic pay which
necessarily EXCLUDES money received in different concepts such as Christmas