G.R. No. L-12011-14 - People vs. Gatchalian

Alfonso Gatchalian, owner/manager of New Life Drug Store in Zamboanga, was charged in four separate informations (Criminal Cases Nos. 2206–2209) with willfully underpaying his employee, Expedite Fernandez, from August 4, 1951 to December 31, 1953, resulting in an alleged P1,016.64 unpaid wage difference, in violation of Section 3 of Republic Act No. 602 (Minimum Wage Law).
On June 19, 1956, Gatchalian pleaded not guilty. On August 29, 1956, his counsel moved to dismiss the informations, arguing that (a) the violation did not constitute a criminal offense but only civil liability, and (b) Section 3 carried no penal clause.

The City Attorney of Zamboanga opposed the motion, asserting that Section 15 of RA 602 imposed criminal penalties for any willful violation of the Act’s provisions and authorized civil recovery of underpaid wages.
After hearings on September 25 and December 3, 1956, the Court of First Instance of Zamboanga granted the motion to dismiss with costs de oficio, cancelled bail, and directed the Department of Labor’s regional representative to file a civil suit for the wage difference. A motion for reconsideration was denied, and the People appealed.

Whether a willful failure to pay the statutory minimum wage under Section 3 of RA 602, which lacks its own penal clause, nevertheless constitutes a criminal offense under Section 15(a) of the same Act.

Whether the informations were defective for citing only Section 3 without the specific penal provision.
Whether penal statutes must be strictly construed to exclude provisions not expressly declared “unlawful.”