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    Kapisanan NG Mga Manggagawa V. MANILA RAILROAD

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    8LYN LAW
    The union representing employees of Manila Railroad Company sought to reverse the lower court's dismissal of its mandamus petition. The union claimed that under Section 62 of Republic Act 2023, loans granted by credit unions to members enjoyed first priority in payroll deductions from employee wages and salaries. However, the Supreme Court affirmed the lower court's decision, finding that Section 62 did not provide credit union obligations first priority status. The law only mandated employers deduct debts from wages and remit them to credit unions, but did not elevate these obligations over other debts. As the statute was unambiguous, the courts were bound to apply its plain meaning without interpreting additional provisions into the law.

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    Kapisanan NG Mga Manggagawa V. MANILA RAILROAD

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    8LYN LAW
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    The union representing employees of Manila Railroad Company sought to reverse the lower court's dismissal of its mandamus petition. The union claimed that under Section 62 of Republic Act 2023, loans granted by credit unions to members enjoyed first priority in payroll deductions from employee wages and salaries. However, the Supreme Court affirmed the lower court's decision, finding that Section 62 did not provide credit union obligations first priority status. The law only mandated employers deduct debts from wages and remit them to credit unions, but did not elevate these obligations over other debts. As the statute was unambiguous, the courts were bound to apply its plain meaning without interpreting additional provisions into the law.

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    STAT CON CASE

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    Kapisanan Ng Mga Manggagawa V. MANILA RAILROAD

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    The union representing employees of Manila Railroad Company sought to reverse the lower court's dismissal of its mandamus petition. The union claimed that under Section 62 of Republic Act 2023, loans granted by credit unions to members enjoyed first priority in payroll deductions from employee wages and salaries. However, the Supreme Court affirmed the lower court's decision, finding that Section 62 did not provide credit union obligations first priority status. The law only mandated employers deduct debts from wages and remit them to credit unions, but did not elevate these obligations over other debts. As the statute was unambiguous, the courts were bound to apply its plain meaning without interpreting additional provisions into the law.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    2K views2 pages

    Kapisanan NG Mga Manggagawa V. MANILA RAILROAD

    Uploaded by

    8LYN LAW
    The union representing employees of Manila Railroad Company sought to reverse the lower court's dismissal of its mandamus petition. The union claimed that under Section 62 of Republic Act 2023, loans granted by credit unions to members enjoyed first priority in payroll deductions from employee wages and salaries. However, the Supreme Court affirmed the lower court's decision, finding that Section 62 did not provide credit union obligations first priority status. The law only mandated employers deduct debts from wages and remit them to credit unions, but did not elevate these obligations over other debts. As the statute was unambiguous, the courts were bound to apply its plain meaning without interpreting additional provisions into the law.

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    Kapisanan ng mga Manggagawa v.

    Manila Railroad Company


    GR L-25316, 28 February 1979 (88 SCRA 616)
    Second Division, Fernando (p): 5 concur, 1 took no part
    Facts: There are no antecedent facts available for this case.
    The union seeks reversal of decision of the lower court dismissing its petition for
    mandamus. The court determined Republic Act 2023 was enacted only to compel the
    employer to make the deduction of the employees debt from the latters salary and turn
    this over to the employees credit union; but which does not convert the credit unions
    credit into a first priority credit.
    Issue: Whether, indeed, the law does not give first priority in the matter of payments to the
    obligations of employees in favor of their credit unions.
    Held: Where the statutory norm speaks unequivocally, there is nothing for the courts to do
    except to apply it. The law, leaving no doubt as to the scope of its operation, must be
    obeyed. The express provisions of the New Civil Code, Articles 2241, 2242 and 2244
    show the legislative intent on preference of credits. In the present case, the applicable
    provision of Republic Act 2023 speaks for itself; there being no ambiguity, it is to be
    applied. If the legislative intent in enacting paragraphs 1 and 2 of Section 62 of RA 2023
    were to give first priority in the matter of payments to the obligations of employees in favor
    of their credit unions, then, the law would have so expressly declared. There is nothing in
    the provision of Republic Act 2023 which provides that obligation of laborers and
    employees payable to credit unions shall enjoy first priority in the deduction from the
    employees wages and salaries.
    The Supreme Court affirmed the appealed decision, without pronouncement as to costs.
    KAPISANAN NG MGA MANGGAGAWA SA MANILA RAILROAD COMPANY
    CREDIT UNION, INC., petitioner-appellant,
    vs.MANILA RAILROAD COMPANY, respondent appellee.
    FACTS:
    -mandamus petition dismissed by the lower court, petitioner-appellant would
    seek a reversal of such decision relying on what it considered to be a right
    granted by Section 62 of the Republic Act No. 2023, more specifically the first
    two paragraphs thereof:
    (1) A member of a cooperative may, notwithstanding the provisions of existing laws,
    execute an agreement in favor of the co-operative authorizing his employer to deduct
    from the salary or wages payable to him by the employer such amount as may be
    specified in the agreement and to pay the amount so deducted to the co-operative in
    satisfaction of any debt or other demand owing from the member to the co-operative.
    ( 2) Upon the exemption of such agreement the employer shall if so required by the cooperative by a request in writing and so long as such debt or other demand or any part
    of it remains unpaid, make the claimant and remit forth with the amount so deducted
    to the co-operative."

    - petitioner contends that under the above provisions of Rep. Act 2023, the
    loans granted by credit union to its members enjoy first priority in the
    payroll collection from the respondent's employees' wages and salaries.
    - Court ruled in favor of respondent and held that:
    STATCON
    STATCON

    there is nothing in the provision of Rep. Act 2023 hereinabove quoted


    which provides that obligation of laborers and employees payable to credit
    unions shall enjoy first priority in the deduction from the employees' wages
    and salaries. The only effect of Rep. Act 2023 is to compel the employer to
    deduct from the salaries or wages payable to members of the employees'
    cooperative credit unions the employees' debts to the union and to pay the
    same to the credit union.
    if Rep. Act 2023 had been enacted, the employer could not be compelled to
    act as the collecting agent of the employees' credit union for the
    employees' debt to his credit union but to contend that the debt of a
    member of the employees cooperative credit union as having first priority
    in the matter of deduction, is to write something into the law which
    does not appear. the mandatory character of Rep. Act 2023 is only to
    compel the employer to make the deduction of the employees' debt from
    the latter's salary and turn this over to the employees' credit union but this
    mandatory character does not convert the credit union's credit into a first
    priority credit.
    If the legislative intent in enacting pars. 1 and 2 of Sec. 62 of Rep. Act 2023
    were to give first priority in the matter of payments to the obligations of
    employees in favor of their credit unions, then, the law would have so
    expressly declared. Thus, the express provisions of the New Civil Code, Arts.
    2241, 2242 and 2244 show the legislative intent on preference of credits
    ISSUE: WON the petitioners interpretation of RA 2023 is correct?
    HELD: NO -that there is nothing in said provision from which it could be
    implied that it gives top priority to obligations of the nature of that payable to
    petitioner, and that, therefore, respondent company did not violate the abovequoted Section 62 of Republic Act 2023.
    - The applicable provision of Republic Act No. 2023 quoted earlier, speaks for
    itself. There is no ambiguity Petitioner-appellant cannot therefore raise any
    valid objection. For the lower court to view it otherwise would have been to alter
    the law. That cannot be done by the judiciary. That is a function that properly
    appertains to the legislative branch.
    -As was pointed out in Gonzaga v. Court of Appeals: "It has been repeated
    time and time again that where the statutory norm speaks unequivocally,
    there is nothing for the courts to do except to apply it. The law, leaving no
    doubt as to the scope of its operation, must be obeyed. Our decisions have
    consistently born to that effect.

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