Week 2 Coverage Table
The table below mirrors the workbook's assigned cases for Week 2 and links each item to its digest page. Entries marked supra re-assign a case already digested earlier in the week; each re-assignment has its own digest page, angled to the new subtopic.
Class. records how the case actually stands to the subtopic it was assigned under — DIRECT (the Court squarely applies the doctrine), ANALOGOUS (it decides the point under a different provision or doctrine), REJECTED (the Court found the doctrine not established), INCIDENTAL (the doctrine is mentioned but the disposition rests elsewhere). Reciting a REJECTED case as if it were DIRECT inverts the holding.
Citation defects in the workbook list. The table above carries the verified citations. Item 5 — NASUREFCO is G.R. No. 101761, not "10176." Item 17 — the respondent is Undersecretary Trajano, not "Tajano," and the petitioner is Wellington Investment and Manufacturing Corp. Item 4 — the petitioner is De La Salle University Medical Center. Items 7, 13 and 14 — the workbook gives no date; Marby is July 28, 2020, Legahi November 18, 1999, and Lagatic January 28, 1998. Item 24 — "Bonues" is a typo for Bonuses. Item 34 — "Tade Unions" is a typo for Trade Unions. Item 43 — "Septmeber," and the docket is G.R. Nos. 174040-41 against Waterfront Insular Hotel Davao. Item 38 — the workbook repeats the respondent's name. Item 1 — Paloma was decided with G.R. No. 156764. Item 41 — the docket carries the L- prefix. Under item 5 of the syllabus the workbook also reads "Service Incentive Leve."
On item 32. Mabeza is re-assigned here for wage distortion, but the decision is an individual minimum-wage claim resolved under Art. 97(f). It says nothing about Art. 124, whose defect is relational — a mandated increase compressing the intended differentials between employee groups — and not mere underpayment. Recite it under 4.d, where it is DIRECT, and use it under 4.g only as the illustration of what wage distortion is not.
Four cases carry two subtopics this week. Auto Bus Transport (items 8 and 20), Mayon Hotel (items 26 and 27), Mabeza (items 28 and 32), and JPL (items 19 and 44). Each pair has its own digest page angled to the subtopic it was assigned under — the classification can differ between them, as it does for Mayon Hotel and Mabeza. Milan (item 31) is also Week 1, item 1.
Recitation Map
One line per case — what it is for, and the categorical holding.
| Case | What it is for | Categorical holding |
|---|---|---|
| Paloma v. PAL | The "government employee" exclusion, tested by the original-charter rule | PAL was never in the civil service; no vested right under E.O. No. 1077, and no law makes private-sector sick leave commutable |
| Seafdec-Aqd v. NLRC | An exclusion that operates on the employer, not the employee | An intergovernmental organization is immune from local jurisdiction — the award is void, and Art. 82 is never reached |
| Malcaba v. ProHealth Pharma | The outer edge of "employee" from the corporate-law side | A by-law-created officer elected by the board is not an employee; the two managerial employees stayed inside |
| De La Salle University Medical Center v. Laguesma | Commingling under the old Art. 245 — a Book V case, not a Book III one | Affiliation with the same federation is not per se commingling; two conditions must concur |
| National Sugar Refineries v. NLRC | Book III coverage decided functionally, not by Book V labels | Supervisors for bargaining purposes may still be "managerial staff" excluded by Art. 82 |
| ClientLogic v. Castro | Managerial-staff status as a matter of proof | All four cumulative elements of Sec. 2(c), Rule I, Book III must be shown; routinary authority is not enough |
| Marby Food Ventures v. Dela Cruz | Field personnel — the second, forgotten requirement | Off-site work alone does not exclude; hours must also be unascertainable, so timetabled drivers are covered |
| Autobus Transport v. Bautista | The two-part field-personnel test, and who supervises time | Company inspectors and dispatchers made his hours ascertainable — not field personnel |
| Durabuilt v. NLRC | "A fair day's wage for a fair day's labor" as a computation rule | Backwages run only over days the business actually operated; no work, no pay absent an illegal lockout |
| Linton Commercial v. Hellera | What an employer must prove before cutting working days | Losses must be proved, substantial, and actual or imminent — a bad year is not enough |
| Sime Darby v. NLRC | Converting a paid "on call" break into a real meal period | Valid — pay attached only because the employee was still working; no diminution, no ULP |
| Philippine Airlines v. NLRC | Whether the meal break is genuinely time off duty | It is — nothing requires taking meals on the premises, and leaving is not abandonment if the employee returns on time |
| Legahi v. NLRC | A seafarer's fixed contractual overtime allowance | The allowance only fixes the rate; overtime must still be proved to have been actually rendered |
| Lagatic v. NLRC | Offsetting premium work against time off | Not allowed without a genuine compressed workweek — but the employee still recovers nothing without proof of work rendered |
| Labor Congress v. NLRC | Whether piece-rate workers fall outside Book III | They do not — the exclusion reaches only field personnel and the unsupervised; pakyao repackers are covered |
| IBAAEU v. Inciong | An implementing rule that enlarges the statute's exclusions | Monthly-paid employees are entitled to holiday pay; the rule and Policy Instruction No. 9 are void |
| Wellington v. Trajano | The divisor that already accounts for every day of the year | A 314-factor monthly salary already pays every regular holiday; no "extra day" when one falls on a Sunday |
| Jose Rizal College v. NLRC | Faculty paid per student contract hour | No pay for regular holidays programmed out in advance; but pay for special holidays and unscheduled cancellations |
| JPL Marketing v. CA | Whether paying above minimum discharges the SIL obligation | It does not — a wage differential is not the same benefit; SIL runs from the second year of service |
| Auto Bus Transport v. Bautista | Commission-paid employees and when SIL prescribes | Commission basis alone does not exclude; prescription runs from refusal to pay on demand or separation |
| Rodriguez v. Park N Ride | Why an unused leave year starts no clock | SIL is commutable — the three-year period begins only on refusal after demand, or on separation |
| House of Sara Lee v. Rey | Who the 13th month benefit is compulsory for | Rank-and-file only; a fiduciary supervisor is outside P.D. No. 851 as modified by M.O. No. 28 |
| Honda Philippines v. Samahan | A CBA benefit paid in full for years, then prorated after a strike | Once paid unconditionally over years the practice vests under Art. 100; the deduction was invalid |
| Atok-Big Wedge v. Atok-Big Wedge Mutual Benefit Ass'n | The governing test for when a bonus is part of wage | Only if promised unconditionally; if it turns on profits or a productivity threshold it is a prize, not wage |
| Asentista v. Jupp | Commissions where the written contract is silent | Art. 97(f) reaches remuneration on a commission basis under a written or unwritten contract — silence is no defense |
| Mayon Hotel Restaurant v. Adana | Enforcing the wage floor without citing Art. 99 or R.A. No. 6727 | "The payment of minimum wages is not dependent on the employer's ability to pay"; the employer bears the burden |
| Mayon Hotel and Restaurant v. Adana | The three requisites for deducting facilities | None proved — and meals required for the employer's own convenience are supplements, never deductible |
| Mabeza v. NLRC | Board, lodging and utilities credited against the minimum wage | Deductible only on proof of the three requisites, and never where the purpose is the employer's convenience |
| Five J Taxi v. NLRC | What Art. 114 deposits may lawfully cover | Only loss of or damage to employer-supplied tools — a boundary-shortage deposit is unauthorised and refundable |
| SHS Perforated Materials v. Diaz | Management prerogative against Art. 116 | Prerogative never includes withholding salary; the only lawful withholding is an Art. 113 deduction |
| Milan v. NLRC and Solid Mills | The standing exception to the Art. 116 prohibition | Terminal pay may be withheld pending return of company property — Art. 113 and Civil Code Art. 1706 supply the exception |
| Mabeza v. NLRC (wage distortion) | What wage distortion is not | An individual underpayment claim is authority for nothing on Art. 124; distortion is a relational defect |
| Metrobank v. NLRC | Whether a differential must vanish entirely | Severe contraction suffices, and a CBA-fixed gap is an "intentional quantitative difference"; correction is not full restoration |
| Bankard Employees Union v. NLRC | Distortion claimed from a voluntary increase in hiring rates | Two Prubankers elements missing, and Art. 124's compulsion does not reach an increase the employer granted on its own |
| Royal Plant v. Coca Cola | What counts as a "benefit" under Art. 100 at all | Chairs are outside the provision — Art. 100 protects only monetary benefits or those with a monetary equivalent |
| San Miguel Corp. v. Layoc, Jr. | Whether overtime pay is a protected benefit | It is not — overtime is contingent on service actually rendered, and managerial employees are excluded from Title I anyway |
| Vergara Jr. v. Coca-Cola | The four-part test for a ripened company practice | One conditional grant to a non-qualifying retiree, specially explained, is not long, regular, consistent and deliberate |
| Del Rio v. DPO Philippines | An isolated instance offered as practice | Two specially-explained payments are not a practice; separation pay denied |
| Davao Fruits Corp. v. ALU | Practice trumping what the law itself would allow | Six years of voluntarily including excludible items in the 13th month base vested the benefit under Art. 100 |
| Standard Chartered Bank v. SCBEU | How long "long, consistent and deliberate" is | Thirteen years of unobjected reimbursements qualified; switching insurers did not extinguish the benefit |
| Globe Mackay v. NLRC | The error exception to non-diminution | A genuine error on a doubtful question of law gives no vested right once corrected |
| Central Azucarera de Tarlac v. CAT Labor Union | The limits of the error exception | No doubtful question existed, and thirty years is not a timely correction — the practice stands |
| Insular Hotel Employees Union v. Waterfront | Diminution the union itself proposed | Art. 100 does not bar a bargaining agent from agreeing to reduce benefits — free collective bargaining includes the right to suspend it |
| JPL v. CA | Whether unused SIL survives the end of employment | It does — the money equivalent remains due even though the leave was never taken and no dismissal occurred |
Study Notes
Article 82 is answered functionally, and sometimes not by Article 82 at all. NASUREFCO is the cleanest statement of the rule: an employee may be supervisory for Book V bargaining purposes and still be an "officer or member of the managerial staff" excluded from Book III, because the Book III test is the character of the work actually performed. ClientLogic turns that into a burden — all four cumulative elements of Sec. 2(c), Rule I, Book III must be proved, and a title will not do it. Marby and Autobus do the same for field personnel, whose definition has two limbs that are constantly collapsed into one: working away from the principal place of business and hours that cannot be determined with reasonable certainty. Three of the eight cases in this group never reach Art. 82 at all — Paloma decides civil-service coverage, Malcaba corporate-officer status, and Seafdec-Aqd the employer's immunity from local jurisdiction.
Non-diminution has two separate gates, and most of the nine cases fail at the first. Gate one: is the thing a "benefit" Art. 100 protects? Royal Plant says chairs are not, and Layoc says overtime pay is not, because it is contingent on service rendered. Gate two: has it ripened — given over a long period, regularly, consistently and deliberately? Davao Fruits (six years) and Standard Chartered (thirteen years) pass; Vergara and Del Rio fail on isolated, specially-explained grants. Globe Mackay and Central Azucarera frame the error exception from opposite sides: a genuine error on a doubtful question of law confers no vested right, but there must actually be a doubtful question, and thirty years is not a timely correction. Insular Hotel is the outlier worth remembering — Art. 100 does not stop a union from bargaining benefits down.
Wage distortion is relational; underpayment is not. Metrobank supplies the working rule — the differential need not vanish, severe contraction is enough, and a CBA-fixed gap counts as an intentional quantitative difference — while making clear that correction restores a substantial, not the identical, gap. Bankard is the boundary: no hierarchy of positions between old and new employees within the same level, and, more fundamentally, Art. 124's compulsory correction is triggered by a mandated increase, not by one the employer granted voluntarily. Mabeza, re-assigned here, is the trap — a minimum-wage case that decides nothing about Art. 124.
Service incentive leave prescribes differently from every other money claim. Auto Bus and Rodriguez both hold that because SIL is commutable, no cause of action arises when a leave year closes unused; the three-year period under Art. 306 begins only on the employer's refusal after demand for commutation, or on separation. JPL completes the picture from the other end: the money equivalent survives the employment relationship even where the employee was never dismissed and never took a day.
Where Week 2 hands off. De La Salle University Medical Center returns in Week 5 assigned to its actual holding on supervisory unions and Art. 245 (now Art. 255), where it is DIRECT rather than INCIDENTAL — the two digests should be read together.