7/1/24, 10:46 AM Case Digest: G.R. No. L-12011-14 - People vs.

Gatchalian

Title
People vs. Gatchalian

Case Ponente Decision Date

G.R. No. L-12011-14 BAUTISTA Sep 29, 1958
ANGELO, J

The Philippine Supreme Court rules that violation of the Minimum Wage Law is a
criminal offense, with both criminal and civil liability, in the case of People v.
Gatchalian, where the defendant was charged with underpaying his employee,
leading to the dismissal of charges against him, but later appealed by the
government.

Case Digest (G.R. No. L-12011-14)

Comprehensive

Facts:
Alfonso Gatchalian was charged with violating Section 3 of Republic Act No. 602
(Minimum Wage Law).
The charges were filed in four separate criminal cases (Nos. 2206, 2207, 2208, and
2209) before the Court of First Instance of Zamboanga.
The alleged violations occurred between August 4, 1951, and December 31, 1953, in
Zamboanga City.
Gatchalian, as owner or manager of New Life Drug Store, employed Expedito
Fernandez as a salesman.
Gatchalian was accused of paying Fernandez a monthly salary between P60 to P90,
below the minimum wage, resulting in an underpayment total of P1,016.64.
On June 19, 1956, Gatchalian pleaded not guilty.
His counsel moved to dismiss the charges, arguing the violation did not constitute a
criminal offense and the section of the law lacked a penal provision.
The City Attorney of Zamboanga opposed, asserting the law imposed both civil and
criminal liabilities for willful violations.
On December 3, 1956, the court dismissed the informations, directing the
Department of Labor to pursue civil action for the underpaid wages.
The government appealed the dismissal.

Issue:

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7/1/24, 10:46 AM Case Digest: G.R. No. L-12011-14 - People vs. Gatchalian

1. Does failing to pay the minimum wage under Section 3 of Republic Act No. 602
constitute a criminal offense under Section 15 of the same Act?
2. Is the information filed against Gatchalian defective for not specifying the penal
provision violated?

Ruling:
1. Yes, failure to pay the minimum wage constitutes a criminal offense under Section
15 of Republic Act No. 602.
2. No, the information is not defective for not specifying the penal provision violated.

Ratio:
Section 15 of Republic Act No. 602 imposes both criminal and civil liabilities for
willful violations of any provisions of the Act, including the requirement to pay the
minimum wage as stipulated in Section 3.
The law's intention is to impose criminal liability on employers who willfully violate
any of its provisions and to attach civil liability for underpayment of wages.
The Court rejected the argument that not explicitly declaring the non-payment of the
minimum wage as unlawful in Section 3 exempts it from criminal penalties.
Such an interpretation would undermine the law’s fundamental purpose of ensuring
a living wage for employees.
The Rules of Court do not require the specific penal provision to be mentioned in the
information.
The trial court erred in dismissing the informations; the cases were remanded for
further proceedings.

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