STATES MARINE CORP vs CEBU SEAMEN'S ASSOC

FACTS:
States Marine Corporation and Royal Line, Inc. (SMC) were engaged in the business
of marine coastwise transportation,employing steamships of hilippine registry. !hey
had a collecti"e bargaining contract with Cebu Seamen#s $ssociation,Inc. (CS$)%n
September &', &()', the SMC filed with the CIR, a petition against SMC. !he *nion
alleged that the officers and men wor+ing on board the petitioners# "essels ha"e not
been paid their sic+ lea"e, "acation lea"e and o"ertime pay, that CS$ threatened or
coerced them to accept a reduction of salaries,obser"ed by other shipowners, that
after the Minimum -age Law had ta+en effect, the petitioners re.uired their
employees on board their "essels, to pay the sum of ./0 for e"ery meal,while the
masters and officers were not re.uired to pay their meals. $ decision was rendered in
fa"or of the union.
ISSUE:
States Marine Corp argued that they suffered financial losses. $lso, the wor+ done on
board was relati"ely easy. $lso, that in enacting Rep. $ct 1o. 20' (Minimum -age
Law), the Congress had in mind that the amount of ./0 per meal, furnished the
employees should be deducted from the daily wages. Is this correct3
HELD & RATIONALE:
!he SC held that such deductions are not authori4ed. In the business of
transportation of passengers and freight, the men who wor+ in a "essel are pro"ided
with free meals by the shipowners, operators or agents, because they hold on to their
wor+ and duties, regardless of 5the stress and strain concomitant of a bad weather,
unmindful of the dangers that lur+ ahead in the midst of the high seas.5 Section 6,
par. f, of the Minimum -age Law, (R.$. 1o. 20'), pro"ides as follows7
(f) *ntil and unless in"estigations by the Secretary of Labor on his initiati"e or on petition of any
interested party result in a different determination of the fair and reasonable "alue, the furnishing of
meals shall be "alued at not more than thirty centa"os per meal for agricultural employees and not more
than forty centavos for any other employees co"ered by this $ct, and the furnishing of housing shall be
"alued at not more than twenty centa"os daily for agricultural wor+ers and not more than forty centa"os
daily for other employees co"ered by this $ct.
8owe"er, section &( states7
S9C. &(. Relations to other labor laws and practices.: 1othing in this $ct shall depri"e an employee of
the right to see+ fair wages, shorter wor+ing hours and better wor+ing conditions nor justify an employer
in "iolating any other labor law applicable to his employees, in reducing the wage now paid to any of his
employees in excess of the minimum wage established under this Act, or in reducing supplements
furnished on the date of enactment.
It would appear that there e;ists a contradiction between the pro"isions, but from a
careful e;amination it is e"ident that Section 6(f) constitutes the general rule, while
section &( is the e;ception. If no supplements are gi"en, under section &(, but
merely facilities, section 6(f) go"erns. !here is no conflict.
It is argued that the food or meals gi"en to the dec+ officers, marine engineers and
unlicensed crew members in .uestion, were mere 5facilities5 which should be
deducted from wages, and not 5supplements5, the two terms are defined as follows7
5Supplements5, therefore, constitute e;tra remuneration or special pri"ileges or benefits gi"en to or
recei"ed by the laborers over and above their ordinary earnings or wages. 5<acilities5, on the other hand,
are items of e;pense necessary for the laborer#s and his family#s e;istence and subsistence so that by
e;press pro"ision of law (Sec. '=g>), they form part of the wage and when furnished by the employer are
deductible therefrom, since if they are not so furnished, the laborer would spend and pay for them ?ust
the same.
In short, the benefit or pri"ilege gi"en to the employee which constitutes an e;tra
remuneration abo"e and o"er his basic or ordinary earning or wage, is supplement,
and when said benefit or pri"ilege is part of the laborers# basic wages, it is a facility.
!he criterion is with the +ind of the benefit gi"en, but its purpose. $s found by the
court that the meals were freely gi"en to crew members prior to $ugust /, &()&, while
they were on the high seas 5not as part of their wages but as a necessary matter in
the maintenance of the health and efficiency of the crew personnel during the
"oyage5, the deductions therein made for the meals gi"en after $ugust /, &()&,
should be returned to them, and the operator should continue gi"ing the same
benefit.