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(a) Identify the controlling doctrine and the relevant actors in a private employer–employee setting where management pays an annual discretionary bonus that is conditional on performance and compliance with internal rules.
(b) Distinguish whether the employer’s proposed “Efficiency Pledge Bonus” (EPB) is a wage or a discretionary benefit and state the test to determine entitlement, including how past practice may affect that determination.
(c) Apply the rule to the following facts and state the likely legal result and possible remedies: BrightForge Robotics, Inc., a private manufacturing firm with 480 employees, adopts an annual 'Efficiency Pledge Bonus' (EPB) of up to PHP 28,000 payable at year-end. The policy states: 'Bonuses are discretionary; there is no guaranteed entitlement; eligibility requires (i) active participation in the Efficiency Initiative for the year, and (ii) meeting defined performance metrics: production index ≥ 1.25 and on-time delivery rate ≥ 98%.' Past practice for the last four years has been to pay the EPB only to employees who satisfy both criteria. This year, 260 participated; 170 satisfied both criteria and were paid; 60 satisfied only one criterion and were not paid; 30 satisfied neither criterion and were not paid. The 60 claim that the EPB is a wage and that denial reduces their compensation and violates the Labor Code by making wages dependent on management whim. The company contends the policy is a valid exercise of management prerogative and that bonuses are discretionary benefits, unless there is an established practice creating a contractual right. (a) Identify the controlling doctrine and the relevant actors; (b) Distinguish whether the 'EPB' is a wage or a discretionary benefit and the test to determine entitlement, including how past practice may affect that determination; (c) Apply the rule to these facts and state the likely legal result and possible remedies.

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