G.R. No. L-19780 - Benguet Consolidated, Inc. vs. Montemayor

The petition was filed by Benguet Consolidated, Inc. (the Consolidated) seeking a writ of mandamus to compel its respondent, Benguet Consolidated, Inc., to deduct specified amounts from the salaries of its employees.
The deduction was requested pursuant to Section 62 of Republic Act No. 2023 (the Philippine Non-Agricultural Cooperative Act), which mandates that employers deduct and remit to a cooperative the sums agreed upon by its members for the payment of any claims or debts.
The Acupan Miners Cooperative Credit Union, composed exclusively of the laborers and employees of the Consolidated, was organized under this Act. After approval of its Articles of Incorporation, By-Laws, and subsequent registration by the Cooperative Administration Office, the cooperative officially commenced operations.

Under the cooperative’s By-Laws, a laborer or employee becomes a member by filing an application that includes a pledge to deposit P100.00 through weekly installments of P8.00, in addition to a membership fee of P1.00.
The application specifically authorizes the credit union’s treasurer to collect the required sums via salary deductions from members employed by the Consolidated.
Although by the cooperative’s internal rules a person does not fully enjoy member rights until payment is completed, Section 3, paragraph 4 of Republic Act No. 2023 deems an approved applicant as a member for the purposes of the Act.

Notice of the required deductions was sent by Atty. Alexander H. Brillantes, acting as legal consultant and accountant for the cooperative, on August 21, 1958.
The appointment and authority of Atty. Brillantes were ratified by the cooperative’s Board of Directors in a meeting held on October 9, 1958.
The Consolidated, upon receiving the notice, objected to the deductions, arguing that they would incur additional clerical expenses and would contravene the Minimum Wage Law.

The Court of First Instance of Baguio City ruled in favor of the cooperative by ordering the respondent to implement the deductions and remit the amounts to the cooperative’s treasurer.
This ruling was affirmed by the Court of Appeals on appeal.
The case was elevated to the Supreme Court via appeal by certiorari, with the main issue being the employer’s legal duty to make the salary deductions as required by Republic Act No. 2023.

Whether the Consolidated has a legal duty to deduct, from the salaries of its employees, the total amount of P100.00 (payable in weekly installments of P8.00 each), plus the additional P1.00 membership fee, for deposit with the cooperative in accordance with Section 62 of Republic Act No. 2023.

Whether the fact that a person’s membership rights are not fully exercisable until after the payment of the membership fee and initial installment affects the applicability of the deduction mechanism under the Act.
Whether the term “any debt or other demand” in Section 62 exclusively covers obligations such as those for seeds, fertilizers, labor, etc., as contemplated in Section 61, or whether it broadly covers the financial obligations related to cooperative membership.
Whether the request for the deduction was validly made by the cooperative through its legal consultant, Atty. Brillantes, rather than directly by the cooperative itself.
Whether the director of the Cooperative Administration Office, who signed the petition, had the proper legal standing and authority to initiate judicial relief in this matter.