Traders Royal Bank vs NLRC, 189 SCRA 274; G. R. No. 88168, August 30, 1990

(Labor Standards –  bonus, diminution of benefits)

Facts: Respondent union filed a letter-complaint against petitioner TRB for the diminution of benefits being enjoyed by the employees since time immemorial, e.g. mid-year bonus, from 2 months gross pay to 2 months basic and year-end bonus from 3 months gross to only 2 months.

Petitioner insisted that it had paid the employees holiday pay. The practice of giving them bonuses at year’s end, would depend on how profitable the operation of the bank had been.

NLRC found TRB guilty of diminution of benefits due to the private respondents and ordered it to pay the said employees’ claims for differentials in their holiday, mid-year, and year-end bonuses.

Issue: Whether or not bonuses are part of labor standards.

Held: No. A bonus is a “gratuity or act of liberality of the giver which the recipient has no right to demand as a matter of right”. It is something given in addition to what is ordinarily received by or strictly due the recipient. The granting of a bonus is basically a management prerogative which cannot be forced upon the employer “who may not be obliged to assume the onerous burden of granting bonuses or other benefits aside from the employee’s basic salaries or wages”.

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