G.R. No. 144664; March 15, 2004
ASIAN TRANSMISSION CORPORATION, petitioner, vs. THE HON. COURT OF APPEALS, et al., respondents.

FACTS

The Department of Labor and Employment (DOLE) issued an Explanatory Bulletin dated March 11, 1993, clarifying that when two regular holidays, such as Araw ng Kagitingan and Good Friday, coincide on a single day (e.g., April 9, 1993), covered employees are entitled to 200% of their basic wage for that unworked day. This bulletin was reproduced on January 23, 1998, applicable to April 9, 1998, which was both Araw ng Kagitingan and Maundy Thursday. Despite this, petitioner Asian Transmission Corporation paid its daily-paid employees only 100% of their basic pay for April 9, 1998. The respondent union, BATLU, protested, leading to the submission of the dispute to voluntary arbitration.
The Panel of Voluntary Arbitrators ruled in favor of the union, directing the petitioner to pay 200% of the regular daily wage for the unworked dual holiday. The Court of Appeals affirmed this decision. The petitioner filed this petition for certiorari, arguing that the DOLE bulletin was invalid and that the CBA and Labor Code provisions on holiday pay should not mandate double payment when two regular holidays coincide on a single calendar day.

ISSUE

Whether an employee is entitled to 200% of the regular daily wage when two regular holidays, such as Araw ng Kagitingan and Maundy Thursday, fall on the same day, even if said day is unworked.

RULING

The Supreme Court dismissed the petition and upheld the entitlement to 200% pay. The legal logic is anchored on a strict interpretation of Article 94 of the Labor Code, which mandates payment of the regular daily wage for each regular holiday. The law enumerates ten regular holidays, and the right to holiday pay attaches to each enumerated day irrespective of their calendrical coincidence. Reducing the payment to 100% for a dual holiday would effectively diminish the number of paid holidays for that year, which is not sanctioned by the law. The Court emphasized that holiday pay is a statutory benefit designed for the worker’s welfare, and any ambiguity in its implementation must be resolved in favor of labor.
Furthermore, the Collective Bargaining Agreement (CBA) between the parties explicitly obligated the company to pay for the listed legal holidays “as required by law.” Since the law requires payment for each holiday, the CBA provision must be interpreted to give full effect to that legal mandate. The DOLE Explanatory Bulletin, while not a rule of judicial character, correctly interprets this legal principle. The Court found no grave abuse of discretion in the appellate court’s decision affirming the arbitral award, as it correctly applied the rule of liberal interpretation in favor of the working class to uphold the substantive right to full holiday compensation.