GR L 12011; (September, 1958) (Digest)
G.R. No. L-12011-14; September 30, 1958
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. ALFONSO GATCHALIAN, defendant-appellee.
FACTS
Alfonso Gatchalian, owner/manager of the New Life Drug Store in Zamboanga City, was charged in four separate informations (Criminal Cases Nos. 2206, 2207, 2208, 2209) with a violation of Section 3 of Republic Act No. 602 (Minimum Wage Law). The charges alleged that from August 4, 1951, to December 31, 1953, he willfully paid his employee, Expedito Fernandez, a monthly salary of P60 to P90, which was less than the legal minimum wage, resulting in a total underpayment of P1,016.64. Upon arraignment, Gatchalian pleaded not guilty. His counsel filed a motion to dismiss, contending that the alleged violation did not constitute a criminal offense but only a civil liability, and that Section 3 of the law carried no penal sanction. The City Attorney opposed, arguing that willful violations were penalized under Section 15 of the same Act. After hearing arguments, the Court of First Instance of Zamboanga issued an order on December 3, 1956, dismissing the informations, cancelling the bail bond, and directing the Department of Labor to institute a civil action for the underpayment. The Government’s motion for reconsideration was denied, prompting this appeal.
ISSUE
Whether the willful failure of an employer to pay the prescribed minimum wage under Section 3 of Republic Act No. 602 constitutes a criminal offense punishable under Section 15(a) of the same Act.
RULING
Yes. The Supreme Court reversed the order of dismissal and remanded the cases for further proceedings.
The Court held that a willful violation of Section 3 of the Minimum Wage Law is a criminal offense punishable under Section 15(a). Section 15(a) explicitly states: “Any person who wilfully violates any of the provisions of this Act shall upon conviction thereof be subject to a fine…” This penal clause is all-embracing and applies to any willful violation of the Act’s provisions, including the fundamental mandate in Section 3 requiring payment of the minimum wage. The law imposes both criminal liability (fine/imprisonment under Sec. 15(a)) and civil liability (recovery of unpaid wages with interest and attorney’s fees under Sec. 15(e)) for such violations. The Court found that the law was patterned after the U.S. Fair Labor Standards Act, where failure to pay the minimum wage is expressly declared unlawful and subject to criminal penalty. While the Philippine law does not contain an explicit declaration that underpayment is “unlawful,” the structure and intent of the statute, particularly the comprehensive penal provision in Section 15(a), lead to the conclusion that willful non-compliance with the minimum wage requirement is a criminal act. The dismissal order was therefore erroneous.