GR L 13667; (March, 1960) (Digest)
G.R. No. L-13667; April 29, 1960
PRIMITIVO ANSAY, ETC., ET AL., plaintiffs-appellants, vs. THE BOARD OF DIRECTORS OF THE NATIONAL DEVELOPMENT COMPANY, ET AL., defendants-appellees.
FACTS
On July 25, 1956, the plaintiffs-appellants (employees) filed a complaint in the Court of First Instance of Manila against the defendants-appellees (the Board of Directors of the National Development Company) praying for a 20% Christmas bonus for the years 1954 and 1955. The lower court, upon the appellees’ motion to dismiss, issued an order dismissing the complaint. The court reasoned that a bonus is an act of liberality and it is not within judicial power to command such liberality. It further noted that the petitioners admitted the appellees were not under a legal duty to give the bonus, and that the court has no power to compel compliance with a mere moral obligation. The plaintiffs’ motion for reconsideration was denied, prompting this appeal. The appellants contend their claim rests on moral grounds or what is defined by law as a natural obligation.
ISSUE
Whether the plaintiffs-appellants have a cause of action to compel the defendants-appellees to grant a Christmas bonus for the years 1954 and 1955.
RULING
No. The order of dismissal is affirmed. The Supreme Court held that the appellants admitted the appellees were not under a legal obligation to give the claimed bonus, and that the grant would arise only from a moral or natural obligation. Citing Article 1423 of the New Civil Code, the Court defined a natural obligation as one not based on positive law but on equity and natural law, which does not grant a right of action to enforce performance. A court can only authorize the retention of what has been delivered after voluntary fulfillment by the obligor. In this case, there was no voluntary performance by the appellees, and the court cannot order it. The Court reiterated its ruling in Philippine Education Co. vs. CIR that from a legal point of view, a bonus is not a demandable and enforceable obligation unless made part of the wage or salary. While the subsequent case of H. E. Heacock vs. National Labor Union stated a bonus may be granted on equitable considerations if it was given in the past, the facts of that case were not the same as the instant one, and thus its ruling was inapplicable.