Unlocking the Right to Minimum Salary Upon Regularization: A Landmark Decision for Philippine Workers

The Supreme Court has settled an important question for Filipino workers: when a company policy promises a minimum salary upon regularization, can the employer refuse to pay it? In Del Monte Fresh Produce (Philippines), Inc. v. Del Monte Fresh Supervisors Union (G.R. No. 225115, January 27, 2020), the Court ruled that once an employee is regularized, the employer must honor the minimum rate set by its own salary policies. This decision affirms that company policies, once issued, become part of the employment contract and are no longer subject to management discretion.

The Facts of the Case

Del Monte Fresh Produce had two company policies governing salaries: a Global Policy on Salary Administration and a Local Policy on Salary Administration. Both policies stated that newly hired employees could be paid below the minimum rate for their job level during probation, but upon regularization, their salary receive the minimum rate, the employer has no discretion to pay less.

• Management prerogative has limits. Employers may set policies, but they cannot violate their own policies once issued, especially when doing so harms employees.
• Labor contracts favor workers. In case of doubt, courts will interpret employment terms in favor of the employee's safety and decent living.
• Check your salary upon regularization. Employees who are regularized should verify that their salary meets the minimum rate stated in company policies or their job level's pay structure.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.