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SAN JUAN DE DIOS HOSPITAL EMPLOYEES ASSOCIATION v. NLRC

FACTS:

The petitioners, who are rank-and-file employee-union officers and members of San Juan De Dios Hospital Employees Association, sent a letter to respondent Juan De Dios Hospital requesting the implementation and payment of the 40 hours/5-day workweek with compensable weekly two days off provided for by Republic Act 5901, as clarified by the Secretary of Labor's Policy Instruction No. 54. The hospital did not give a favorable response, so the petitioners filed a complaint before the NLRC. The Labor Arbiter dismissed the complaint, and the NLRC affirmed the decision. The petitioners then filed a motion for reconsideration, which was denied. This petition was filed, alleging grave abuse of discretion on the part of the NLRC in concluding that Policy Instructions No. 54 "proceeds from a wrong interpretation of RA5901" and Article 83 of the Labor Code. The core issue is whether Policy Instructions No. 54 issued by then Labor Secretary Franklin M. Drilon is valid or not. Policy Instruction No. 54 clarifies the enforcement policy on the working hours and compensation of hospital/clinic personnel. It purports to implement Republic Act No. 5901, which was enacted on June 21, 1969, but the NLRC correctly ruled that Republic Act No. 5901 has long been repealed with the passage of the Labor Code on May 1, 1974. Article 83 of the Labor Code, which incorporates or reproduces the basic provisions of Republic Act No. 5901, may support Policy Instructions No. 54.

ISSUES:

  1. Whether or not Policy Instructions No. 54 issued by then Labor Secretary Franklin M. Drilon is valid.

RULING:

  1. Policy Instructions No. 54 is invalid. It is inconsistent with Article 83 of the Labor Code and Republic Act No. 5901, and has been declared void.

PRINCIPLES:

  • The statutory language must be clear and taken exactly as it says without additions or revisions.

  • Administrative interpretations of laws are advisory and can be struck down if they deviate from the statutory provisions.

  • Republic Act No. 5901 was repealed with the passage of the Labor Code, and only Article 83 of the Labor Code remains relevant for determining working hours and compensation for health personnel.