J.P. Heilbronn Co. vs. National Labor Union

An employee who voluntarily absents from work to attend a conference or hearing in a labor case against the employer is not entitled to wages for the period of absence, applying the principle of "a fair day's wage for a fair day's labor."

J.P. Heilbronn Co. was a domestic corporation domiciled in the City of Manila, and the National Labor Union was a labor organization organized under the provisions of Commonwealth Act 213. The dispute involved the company and its employees, who were members of the J.P. Heilbronn Employees Association affiliated with the National Labor Union.

On July 12, 1948, the Secretary of Labor certified to the Court of Industrial Relations a dispute between the National Labor Union and J.P. Heilbronn Co. The case involved the company and its employees, who were members of the J.P. Heilbronn Employees Association affiliated with the National Labor Union. During the pendency of the case, Armando Ocampo and Protacio Ty, the President and Secretary of the local union respectively, attended conferences and hearings before the CIR, in some cases assisting the lawyer who represented them.

Because of their absence from work during these attendances, the company deducted ₱88 from Ocampo's salary and ₱64.65 from Ty's salary, corresponding to the days or hours they were absent. The National Labor Union filed a motion before the CIR on behalf of Ocampo and Ty, praying that the court order the company to pay these amounts to the two men. Despite the opposition of the company, Associate Judge V. Jimenez Yanson granted the motion.

The company subsequently filed a petition for reconsideration of the order, which was denied by the Court of Industrial Relations en banc. The company then elevated the case to the Supreme Court seeking to reverse the order.

• Inconsistency with Precedent: Petitioner argued that the CIR's action was inconsistent with its previous rulings regarding payment of wages to laborers who had voluntarily absented themselves from work, specifically citing cases where strikers were denied wages for days not worked even if the strike was legal.

• Payment of Wages During Absence: Whether employees who voluntarily absent themselves from work to attend conferences and hearings before the CIR are entitled to reimbursement of their wages for the period of such absence.

• Payment of Wages During Absence: No. The order directing reimbursement was set aside, applying the equitable tenet of "a fair day's wage for a fair day's labor."

• Payment of Wages During Absence: The Court relied on the equitable principle that "a fair day's wage for a fair day's labor" governs the relation between management and employee. If no work is performed, no wage is due, unless the employee was able, willing, and ready to work but was illegally locked out, dismissed, or suspended. The Court noted that the CIR's action contradicted its own precedents in San Miguel Brewery, Inc. vs. National Union, et al. and Federation Obrera de Filipinas vs. Philippine Rubber Projects Co., Inc., where wages were denied to strikers even for legal strikes because no labor was performed. By analogy, employees who voluntarily absent themselves to litigate against the employer cannot demand wages for that period, as it is unjust to fight or litigate against the employer on the employer's time. The Court suggested alternatives such as seeking reimbursement from the union or charging the absence against vacation leave.

• A fair day's wage for a fair day's labor — The fundamental rule governing employer-employee relations is that wages represent compensation for labor actually performed. If there is no work performed by the employee, there can be no wage or pay, unless the laborer was able, willing, and ready to work but was illegally locked out, dismissed, or suspended. Applied here to deny wages to employees who voluntarily absented themselves to attend labor hearings, as it is inequitable for an employee to litigate against the employer on the employer's time.

• "The age-old rule governing the relation between labor and capital or management and employee is that a 'fair day's wage for a fair day's labor.' If there is no work performed by the employee there can be no wage or pay, unless of course, the laborer was able, willing and ready to work but was illegally locked out, dismissed or suspended." — This passage articulates the ratio decidendi of the case, defining the controlling doctrine on wage payment and the exceptions thereto.
• "It is hardly fair or just for an employee or laborer to fight or litigate against his employer on the employer's time." — This statement underscores the equitable rationale behind denying wages to employees who voluntarily absent themselves to pursue labor claims against the company.

• San Miguel Brewery, Inc. vs. National Union, et al. — Cited as a CIR precedent where wages were denied to strikers for days not worked, based on the equitable tenet of a fair day's wage for a fair day's labor.
• Federation Obrera de Filipinas (FOF) vs. Philippine Rubber Projects Co., Inc. — Cited as another CIR precedent denying wages to strikers even when the strike was justified, because no labor was performed during the strike.

• Commonwealth Act 213 — Referenced as the law under which the National Labor Union was organized, providing the statutory context for the labor dispute.

Paras, C.J., Feria, Pablo, Bengzon, Padilla, Tuason, Reyes, Jugo, Bautista Angelo and Labrador, JJ., concur.