WELLINGTON INVESTMENT v. CRESENCIANO B. TRAJANO

FACTS:

Wellington Investment and Manufacturing Corporation (Wellington) owns and operates Wellington Flour Mills. In August 1991, a routine inspection was conducted which revealed that Wellington failed to pay its monthly-paid employees for regular holidays falling on a Sunday. Wellington argued that the employees' monthly salary already includes holiday pay for all regular holidays, and it insisted that there was no legal basis for the alleged non-payment. However, the Regional Director rejected Wellington's arguments and ordered them to compensate their employees for four extra working days. Wellington filed a motion for reconsideration, which was treated as an appeal by the Undersecretary. The Undersecretary affirmed the Regional Director's order and directed Wellington to pay their employees for six additional working days resulting from regular holidays falling on Sundays in previous years. In response, Wellington filed a petition for certiorari to nullify the orders. The Supreme Court issued a temporary restraining order to halt the enforcement of the orders.

ISSUES:

  1. The main issue in this case is whether a monthly-paid employee, receiving a fixed monthly compensation, is entitled to an additional pay aside from his usual holiday pay, whenever a regular holiday falls on a Sunday.

RULING:

  1. The Supreme Court ruled that a monthly-paid employee is not entitled to additional pay for regular holidays falling on a Sunday. The monthly salary the employee receives already includes payment for all the working days in a month as well as all the 10 unworked regular holidays within a year. Therefore, there is no legal basis for the finding of alleged non-payment of regular holidays falling on a Sunday.

PRINCIPLES:

  • Every worker is entitled to be paid his regular daily wage during regular holidays, even if the worker does no work on these holidays.

  • Monthly-paid employees are entitled to a fixed monthly compensation that serves as compensation for all days in the month, whether worked or not.

  • Monthly-paid employees are entitled to receive the entire monthly salary, regardless of the number of working days in a month.

  • Employers cannot deduct the proportionate amount corresponding to the days when no work was done due to special holidays or fortuitous causes.