Civil Law

PRIMITIVO ANSAY vs. NATIONAL DEVELOPMENT COMPANY,G.R. No. L-13667 April 29, 1960 Natural Obligations v. Civil Obligations

FACTS:

On July 25, 1956, appellants filed a complaint praying for a 20% Christmas bonus for the years 1954 and 1955.

The court a quo on appellees’ motion to dismiss, issued the following order:

The trial court dismissed the complaint and saying that the Court does not see how petitioners may have a cause of action to secure such bonus because:

(a) A bonus is an act of liberality and the court takes it that it is not within its judicial powers to command respondents to be liberal;

(b) Petitioners admit that respondents are not under legal duty to give such bonus but that they had only ask that such bonus be given to them because it is a moral obligation of respondents to give that but as this Court understands, it has no power to compel a party to comply with a moral obligation (Art. 142, New Civil Code).

(b) Petitioners admit that respondents are not under legal duty to give such bonus but that they had only ask that such bonus be given to them because it is a moral obligation of respondents to give that but as this Court understands, it has no power to compel a party to comply with a moral obligation (Art. 142, New Civil Code).

ISSUE:

Whether or not there exists a cause of action in their complaint because their claim rests on moral grounds or what in brief is defined by law as a natural obligation.

RULING:

Article 1423 of the New Civil Code classifies obligations into civil or natural. “Civil obligations are a right of action to compel their performance. Natural obligations, not being based on positive law but on equity and natural law, do not grant a right of action to enforce their performance, but after voluntary fulfillment by the obligor, they authorize the retention of what has been delivered or rendered by reason thereof”.

It is thus readily seen that an element of natural obligation before it can be cognizable by the court is voluntary fulfillment by the obligor. Certainly retention can be ordered but only after there has been voluntary performance. But here there has been no voluntary performance. In fact, the court cannot order the performance.

As held in the case of Philippine Education Co. vs. CIR and the Union of Philippine Education Co., Employees:

From the legal point of view a bonus is not a demandable and enforceable obligation. It is so when it is made a part of the wage or salary compensation.

Premises considered, the order appealed from is hereby affirmed.

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