People v. Manangco
REITERATIONFacts
The Antecedents: Appellant Venancio Manangco contracted the services of several laborers for the loading and unloading of cement sacks in Mariveles, Bataan. The shipment belonged to the National Steel and Shipyard Company, and the contract for loading and unloading was with Pan-Philippine Shipping Co. The laborers were to be paid by appellant Manangco. The loading and unloading finished on February 26, 1952, but appellant failed and refused to pay the wages due to the laborers, amounting to P477.34. Procedural History: The accused was charged in the Court of First Instance of Manila with a violation of Commonwealth Act No. 303 in relation to Article 315 of the Revised Penal Code. The trial court found him guilty and sentenced him to imprisonment, to indemnify the complainants, with subsidiary imprisonment in case of insolvency, and to pay costs. The defendant appealed to the Court of Appeals, which certified the case to the Supreme Court. The Petition: The appellant contended that Commonwealth Act No. 303 was repealed by Republic Act No. 602 (Minimum Wage Law), that non-payment of wages does not constitute estafa under Republic Act No. 602, and that he should be acquitted. He argued he was an independent contractor and a sub-contractor, and that the Pan-Philippine Shipping Co. refused to reimburse him for expenses, leading to his inability to pay the laborers.
Issue(s)
Whether Commonwealth Act No. 303 was repealed by Republic Act No. 602. Whether the non-payment of wages constitutes estafa under Republic Act No. 602. Whether the accused is guilty of violating the applicable labor law.
Ruling
The Supreme Court modified the decision of the lower court. It found the defendant and appellant guilty of a violation of Section 10-(h) in connection with Section 15 of Republic Act No. 602. He was sentenced to pay a fine of P1,000, to indemnify the complainants in the total amount of P477.33, or suffer corresponding subsidiary imprisonment in case of insolvency, and to pay the costs.
Ratio Decidendi
On the repeal of Commonwealth Act No. 303 by Republic Act No. 602: The Court held that the failure of the defendant to pay wages fell within the purview of both Commonwealth Act No. 303 and Republic Act No. 602. However, since the accused cannot be prosecuted twice for the same offense, the Court concluded that Republic Act No. 602, at least concerning the issues involved, covers and repeals the provisions of Commonwealth Act No. 303 on the matter of wage payment. The Court noted that even though the prosecution was under Commonwealth Act No. 303, the information contained averments that fully constituted a violation of Section 15 of Republic Act No. 602. Therefore, the Court found no obstacle in declaring the defendant guilty of violating Republic Act No. 602, with the penalty to be imposed according to the latter law. On whether non-payment of wages constitutes estafa under Republic Act No. 602: The Court did not directly rule on whether non-payment of wages constitutes estafa under Republic Act No. 602. Instead, it focused on the violation of the labor laws themselves. The prosecution was for a violation of Commonwealth Act No. 303 in relation to Article 315 of the Revised Penal Code (estafa). However, the Court found that the elements of a violation of Republic Act No. 602 were present in the information. The Court's decision to convict under Republic Act No. 602 implies that the specific violation charged under the Revised Penal Code was superseded by the more specific labor legislation, or that the elements of the labor law violation were sufficiently pleaded and proven. On the guilt of the accused: The Court found the accused guilty of violating Section 10-(h) in connection with Section 15 of Republic Act No. 602. The facts established that the appellant contracted laborers, the work was completed, and despite demands, he failed to pay their wages. The contract stipulations, particularly those absolving the Pan-Philippine Shipping Co. from responsibility for non-payment to laborers and placing the onus on Manangco, were noted. The Court considered the failure to pay wages as a violation of the labor law, specifically the requirement for timely payment of wages. The penalty was imposed in accordance with Section 15 of Republic Act No. 602.
Main Doctrine
While the accused was prosecuted under Commonwealth Act No. 303 for non-payment of wages, the elements of a violation of Section 15 of Republic Act No. 602 were present in the information. Consequently, the accused can be found guilty of violating Republic Act No. 602, with the penalty imposed according to its provisions, as Republic Act No. 602, in so far as the issues involved are concerned, covers and repeals the provisions of Commonwealth Act No. 303.