Case Summary (G.R. No. 45748)
Charges and Allegations
The defendant was charged with a violation of Act No. 2549, as amended by Acts Nos. 3085 and 3958. The prosecution alleged that between September 9 and October 28, 1936, Reyes willfully and illegally failed to pay a stenographer, Severa Velasco de Vera, her agreed salary of P 35 for the said period, despite repeated demands for payment.
Demurrer and Court Decision
In response to the charges, Reyes interposed a demurrer, arguing that the allegations did not constitute an offense and that the applicable laws were unconstitutional. The court upheld the demurrer, declaring the last part of Section 1 of Act No. 2549 unconstitutional for violating the constitutional prohibition against imprisonment for debt, and dismissed the case, with costs assigned to the government.
Appeal by Solicitor-General
The Solicitor-General contested the lower court's ruling, claiming that it erred in declaring Act No. 3958 unconstitutional and in dismissing the case against Reyes. The pertinent provisions of the law stated that it was unlawful for employers to withhold employee wages and established penalties for violations.
Examination of the Law
Section 1 of Act No. 2549, as last amended, prohibits employers from compelling employees to accept payment in forms other than legal tender and mandates timely payment of salaries. Violators face fines or imprisonment. The law explicitly states that the employer must pay salaries at prescribed intervals or prove that payment was impossible.
Constitutional Considerations
The court ruled that the provision under scrutiny did not violate the constitutional prohibition against imprisonment for debt. The ruling underscored that the legal language specifically addressed employers who refused to pay wages they were capable of paying, likening such misconduct to fraudulent behavior.
Legislative Authority
The court acknowledged the government's police power, which allows the enactment of laws designed to promote public welfare an
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Case Overview
- The case involves the defendant, Franco Veba Reyes, who was charged with a violation of Act No. 2549, as amended by Acts Nos. 3085 and 3958.
- The proceedings took place in the Court of First Instance of Manila, initiated by the assistant city fiscal.
- The allegation described the refusal of Reyes, as president and general manager of the Consolidated Mines, to pay his stenographer, Severa Velasco de Vera, her due salary of P 35 a month from September 9 to October 28, 1936, despite her repeated demands.
Procedural History
- The defendant interposed a demurrer, claiming that the facts alleged did not constitute an offense, and argued that the penal laws were unconstitutional.
- The trial court sustained the demurrer and declared the last part of section 1 of Act No. 2549 unconstitutional, citing a violation of the constitutional prohibition against imprisonment for debt.
- The court dismissed the case with costs de oficio.
- The fiscal subsequently appealed the order, contesting the court's ruling on the constitutionality of Act No. 3958.
Legal Provisions Discussed
- Act No. 2549, as amende