35 national level. Furthermore, the chronically low and lengthy process of regularization is clearly shown by the fact that only a small percentage of the workers surveyed were regular workers, and an even smaller portion achieved this status within the mandatory 5-6 month period. Regarding the implementation of labor standards, the national government's Labor Laws Compliance System (LLCS) faces many issues. As noted by the DOLE gap report, the national labor inspection system is plagued with the lack of qualified labor inspectors, the fact that existing penalties are low, and the enforcement of regulations and findings are weak, compromising the extent of employer compliance.42 Meanwhile, the lack of a national minimum wage is also a source of concern. Once again, the CESCR report is a useful reference for assessing the status of wages in the country. The Wage Rationalization Act of 1989, with its abolition of the national minimum wage through Congress towards a tripartite body, is riddled with the lack of genuine workers' participation in wage-setting. Its implementation of a two-tier wage system sets a "floor wage" based on the poverty threshold, often far below the minimum wage rate. Furthermore, compliance is problematic. Similar to the LLCS, the punishment for non- payment of minimum wages is "lenient and non-dissuasive."43 As a result, not only is the minimum wage coverage low, it is often far too insufficient for working families.44 Citing data from the Philippine statistic authority, labor group Partido Manggagawa claimed in a statement that: "We should remember that many workers, many of them women, are paid even less than the minimum. In the NCR, there are 1 million minimum wage earners but more than 800,000 workers are paid below the minimum. It is worse nationwide: 2.4 million minimum wage earners but 8 million paid below the minimum."45 42 Joyce Anne S. Lumactud, Gap Analysis of ILO Convention No. 81 (Labor Inspection), at viii, available at https://ils.dole.gov.ph/rights-at-work/2016-rw/gap-analysis-of-ilo-convention-no-81labour-inspection (last accessed November 5, 2022). 43 U.N. Economic And Social Council, Concluding Observations On The Combined Fifth And Sixth Periodic Reports Of The Philippines ¶ 29 E/C.12/PHL/CO/5-6 (October 26, 2016). 44 Ian Nicolas Cigaral, ‘Philippines one of the worst countries to live for minimum wage earners’, PHILSTAR, January 14, 2020, available at https://www.philstar.com/business/2020/01/14/1984769/philippines-one-worst-countries-liveminimum-wage-earners (last accessed November 20, 2022). 45 Catherine Gonzales, Labor group says salaries of low-paid workers must increase faster, INQUIRER, January 27, 2022, available at https://newsinfo.inquirer.net/1546142/labor-group-says-salaries-of-low-paid-workers-mustincrease-faster (last accessed November 20, 2022).

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