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PNB vs. Cruz, Agripino et. al
Case Digest
Course
Juris Doctor
7 Documents
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University of Southeastern Philippines
Academic year: 2023/2024
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Case No. 12 Philippine National Ban vs. Teresita Cruz, Jose Agripino et. al.. (December 18, 1989) Topic Concurrence and Preference of Credits Digested by Dessa L. Caballero Doctrine: The conflict between Article 110 of the Labor Code and Article 2241 to 2245 of the Civil Code must be resolved in favor of the former—workers’ lien take precedence over any other claim. A contrary ruling would defeat the purpose for which Article 110 was intended (protection of the working class) Characters & their Roles: Petitioner: Philippine National Bank Respondents: Teresita Cruz, Jose Agripino, Bernardo Bauzon, Lucrecia Bilbao, Ma. Luisa Cabrera, Francis Baaclo, Guadalupe Camacho, Luz De Leon, Mike Villaverde, Nepomuceno Medina, Edgardo Mendoza, Jennifer Velez, Amelia Medina, Eduardo Espejo And Ricardo Batto, Facts:
- The case arose from a dispute between Philippine National Bank (PNB) and a group of workers (Cruz, et. al) on the matter of the latter’s unpaid wages and termination pay.
- The workers were employed by Aggregate Mining Exponents (AMEX) which laid of 70% of its employees due to business reverses.
- The remaining 30% of employees, including herein respondents, while retained, did not receive their wages from the laying off in 1980 until July 1982 when AMEX completely ceased operations and entered into an operating agreement with TM San Andres Development Corporation.
- In response, the unpaid employees sought redress from the Labor Arbiter (LA) who found their claim valid and meritorious. The LA ordered the complainants to be paid respectively.
- If AMEX was unable to pay, the same shall be satisfied from the proceeds of the machineries and equipment being operated by TM San Andres either by operating agreement w/ respondent AMEX or through lease of the same from PNB.
- PNB, mortgagee-creditor of AMEX, appealed the LA’s decision arguing that the workers’ lien should only cover unpaid wages and not termination pay. However, the NLRC affirmed LA’s decision.
- Hence, a petition for certiorari was filed by PNB. Issue: WON the workers’ lien take precedence over any other claim. Ruling:
- Art. 110 of the Labor Code provides that: “In the event of bankruptcy or liquidation of an employer's business, his workers shall enjoy first preference as regarding their unpaid wages and other monetary claims, any provision of law to the contrary notwithstanding. Such unpaid wages and monetary claims, shall be paid in full before claims of the government and other creditors may be paid”
- The phrase "any provision of law to the contrary notwithstanding" indicates that such preference shall prevail despite the order set forth in Articles 2241 to 2245 of the Civil Code. No exceptions were provided under the said article, henceforth, none shall be considered.
- Furthermore, the Labor Code was signed into Law decades after the Civil Code took effect. Whenever two statutes of different dates and of contrary tenor are of equal theoretical application to a particular case, the statute of later date must prevail being a later expression of legislative will. Applying the aforecited case in the instant petition, the Civil Code provisions cited by the petitioner must yield to Article 110 of the Labor Code.
- the conflict between Article 110 of the Labor Code and Article 2241 to 2245 of the Civil Code must be resolved in favor of the former. A contrary ruling would defeat the purpose for which Article 110 was intended; that is, for the protection of the working class, pursuant to the never-ending quest for social justice.
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PNB vs. Cruz, Agripino et. al
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University: University of Southeastern Philippines
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Case No. 12
Philippine National Ban vs. Teresita Cruz, Jose Agripino et. al..
(December 18, 1989)
Topic
Concurrence and Preference of Credits
Digested by
Dessa L. Caballero
Doctrine: The conflict between Article 110 of the Labor Code and Article 2241 to 2245 of
the Civil Code must be resolved in favor of the former—workers’ lien take precedence over any
other claim. A contrary ruling would defeat the purpose for which Article 110 was intended
(protection of the working class)
Characters & their Roles:
Petitioner: Philippine National Bank
Respondents: Teresita Cruz, Jose Agripino, Bernardo Bauzon, Lucrecia Bilbao, Ma. Luisa
Cabrera, Francis Baaclo, Guadalupe Camacho, Luz De Leon, Mike Villaverde, Nepomuceno
Medina, Edgardo Mendoza, Jennifer Velez, Amelia Medina, Eduardo Espejo And Ricardo Batto,
Facts:
• The case arose from a dispute between Philippine National Bank (PNB) and a group of
workers (Cruz, et. al) on the matter of the latter’s unpaid wages and termination pay.
• The workers were employed by Aggregate Mining Exponents (AMEX) which laid of 70%
of its employees due to business reverses.
• The remaining 30% of employees, including herein respondents, while retained, did not
receive their wages from the laying off in 1980 until July 1982 when AMEX completely
ceased operations and entered into an operating agreement with TM San Andres
Development Corporation.
• In response, the unpaid employees sought redress from the Labor Arbiter (LA) who found
their claim valid and meritorious. The LA ordered the complainants to be paid respectively.
• If AMEX was unable to pay, the same shall be satisfied from the proceeds of the
machineries and equipment being operated by TM San Andres either by operating
agreement w/ respondent AMEX or through lease of the same from PNB.
• PNB, mortgagee-creditor of AMEX, appealed the LA’s decision arguing that the workers’
lien should only cover unpaid wages and not termination pay. However, the NLRC affirmed
LA’s decision.
• Hence, a petition for certiorari was filed by PNB.
Issue: WON the workers’ lien take precedence over any other claim.
Ruling:
• Art. 110 of the Labor Code provides that: “In the event of bankruptcy or liquidation of
an employer's business, his workers shall enjoy first preference as regarding their
unpaid wages and other monetary claims, any provision of law to the contrary
notwithstanding. Such unpaid wages and monetary claims, shall be paid in full before
claims of the government and other creditors may be paid”
• The phrase "any provision of law to the contrary notwithstanding" indicates that
such preference shall prevail despite the order set forth in Articles 2241 to 2245 of
the Civil Code. No exceptions were provided under the said article, henceforth, none shall
be considered.
• Furthermore, the Labor Code was signed into Law decades after the Civil Code took
effect. Whenever two statutes of different dates and of contrary tenor are of equal
theoretical application to a particular case, the statute of later date must prevail being a
later expression of legislative will. Applying the aforecited case in the instant petition,
the Civil Code provisions cited by the petitioner must yield to Article 110 of the Labor
Code.
• the conflict between Article 110 of the Labor Code and Article 2241 to 2245 of
the Civil Code must be resolved in favor of the former. A contrary ruling would defeat
the purpose for which Article 110 was intended; that is, for the protection of the working
class, pursuant to the never-ending quest for social justice.
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