G.R. No. 144322 . February 6, 2007.
Metropolitan Bank and Trust Company, Inc., Petitioner, vs. National Wages and Productivity Commission and Regional Tripartite Wages and Productivity Board – Region II, Respondents.

FACTS

The Regional Tripartite Wages and Productivity Board (RTWPB) of Region II issued Wage Order No. R02-03, granting an across-the-board daily wage increase of ₱15.00 to all private sector employees in the region. The Wage Order took effect on January 1, 1996. Metropolitan Bank and Trust Company (Metrobank), which maintains branches in Region II but has its principal place of business and a unified wage structure based in the National Capital Region (NCR), sought exemption. It argued that its employees in Region II were already receiving wages higher than the NCR minimum and the new regional order. The RTWPB and the National Wages and Productivity Commission (NWPC) denied the exemption, ruling that the Wage Order covered all private establishments in the region irrespective of any voluntary adoption of higher wage rates from other regions.
Metrobank did not file a formal appeal with the NWPC within the 10-day period prescribed by the Wage Order. Instead, it subsequently filed a Petition for Certiorari and Prohibition with the Court of Appeals (CA) seeking to nullify the Wage Order. The CA denied the petition, ruling that the extraordinary writs were improper and that the Wage Order was valid. Metrobank elevated the case to the Supreme Court.

ISSUE

The primary issue is whether Wage Order No. R02-03, which mandates an across-the-board increase to all employees in Region II regardless of their current wage rates, is a valid exercise of the RTWPB’s authority under Republic Act No. 6727 (the Wage Rationalization Act).

RULING

The Supreme Court dismissed the petition and upheld the validity of Wage Order No. R02-03. The Court ruled that the RTWPB acted within its delegated authority. Republic Act No. 6727 authorizes Regional Boards to prescribe minimum wage rates for all workers and employees in their respective regions. The law does not limit the Boards’ authority to granting increases only to those receiving below the existing minimum wage. An “across-the-board” increase is a recognized method of raising the wage floor; it uniformly increases the prevailing minimum wage, thereby benefiting all workers, including those already at or above the old minimum. The Court emphasized that the wage-fixing power is legislative in character, and the Boards have broad discretion to determine the appropriate form of increase after considering the statutory economic criteria. The fact that Metrobank implements a unified, higher wage structure from Manila does not exempt its regional branches from complying with the mandatory minimum wage set by the RTWPB for Region II. The Court also noted that Metrobank’s failure to exhaust administrative remedies by not timely appealing the Wage Order to the NWPC weakened its position.