G.R. No. 22008 - People vs. Pomar

On October 26, 1923, the Manila prosecuting attorney filed a complaint in the Court of First Instance against Julio Pomar, manager of La Flor de la Isabela tobacco factory, for violating sections 13 and 15 of Act No. 3071 by refusing to pay P 80 in maternity wages to Macaria Fajardo for thirty days before and after her confinement on August 12, 1923.
Pomar demurred on ground that the alleged facts did not constitute an offense; the demurrer was overruled. He then admitted all factual allegations at trial but challenged the constitutionality of the maternity-leave provision.
The trial court found him guilty, fined him P 50 (with subsidiary imprisonment for insolvency), and ordered him to pay costs. Pomar appealed, assigning as error the overruling of his demurrer, his conviction, and the refusal to declare section 13 unconstitutional.

Section 13, Act No. 3071: obliges every employer of women in any “factory, shop or place of labor” to grant thirty days’ paid leave before and after confinement, and penalizes unjust discharge by two months’ unpaid wages.
Section 15, Act No. 3071: prescribes a fine of P 50–250 and/or imprisonment of 10 days–6 months for violations; corporate officers are criminally responsible.

Pomar contends the maternity-leave requirement exceeds the police power and violates the constitutional guarantee of liberty and due process to contract.
The key question: are sections 13 and 15 a reasonable and lawful exercise of the state’s police power?

Whether sections 13 and 15 of Act No. 3071 are within the police power’s scope.
Whether section 13’s mandatory maternity-leave pay provision violates the constitutional liberty to contract and due process.