Wage Includes Allowance or Commission?

Here's a question raised by Mr. Louie Ebron on September 1, 2017 at 3:56PM. Below is the suggested answer of Project Jurisprudence.

I partly agree. His sales commission should be included in the computation of separation pay. However, his allowances need not be included.
Under Book III of the Labor Code, wages shall mean remuneration or earnings capable of being expressed in money paid by an employer to his employee for work done or to be done or for services rendered or to be rendered. In Philippine Duplicators v. NLRC, the Supreme Court held that sales commissions are an integral part of basic salary. However, Cebu Institute of Technology v. Ople has held that allowances are excluded in the computation since they are not remuneration for work or services done or rendered. ADVERTISEMENT: Work from home! Be an online English tutor. Earn at least PHP100/hour.

In the case at bar, Marvin is correct in asserting that his sales commission should be included in the computation but is wrong regarding his allowances. Hence, absent any collective bargaining agreement stating otherwise between XYZ Pharmaceutical and Marvin's union, allowances cannot be so included. Hence, I partly agree with Marvin.