G.R. No. L-45748; April 5, 1939
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. FRANCO VERA REYES, defendant-appellee.

FACTS

The defendant, as president and general manager of Consolidated Mines, was charged with violating Act No. 2549, as amended, for willfully and illegally refusing to pay the salary of his stenographer for a specified period despite repeated demands. The accused filed a demurrer, arguing the facts did not constitute an offense and that the law penalizing it was unconstitutional. The trial court sustained the demurrer, declaring the last part of section 1 of Act No. 2549, as amended by Act No. 3958 , unconstitutional for violating the constitutional prohibition against imprisonment for debt, and dismissed the case. The fiscal appealed.

ISSUE

Whether the last part of section 1 of Act No. 2549, as amended by Act No. 3958 —which penalizes an employer’s failure to pay employees’ salaries on time—is unconstitutional for violating the prohibition against imprisonment for debt.

RULING

No. The Supreme Court reversed the trial court’s order. The challenged provision is a valid exercise of police power. It punishes an employer who, being able to pay, unjustifiably refuses to pay salaries on the prescribed dates (the 15th or last day of the month, or Saturday of each week, with a two-day extension). The offense involves an element of fraud or deceit, similar to estafa, and is not a simple non-payment of debt. The constitutional prohibition against imprisonment for debt does not apply to acts involving fraud or to penal statutes enacted under the state’s police power to promote the general welfare and protect laborers from abuse. The law is designed to prevent employers from exploiting workers who might otherwise lack the means to pursue costly civil actions. The case was remanded for trial.

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