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    Philippine Education Co. V CIR and NUL: From A Legal Point of View A Bonus Is

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    Joshua Alexander Calaguas
    The petitioners filed an action demanding a 20% Christmas bonus for two years against the respondents. The trial court dismissed the case, finding that a bonus is an act of liberality that the court had no power to compel. The petitioners argued on appeal that they had a cause of action based on a moral or natural obligation of the respondents. The Supreme Court affirmed the dismissal, holding that a natural obligation like a bonus does not grant a right to demand performance, only a right to retain anything voluntarily fulfilled by the obligor, which had not occurred in this case.

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    Philippine Education Co. V CIR and NUL: From A Legal Point of View A Bonus Is

    Uploaded by

    Joshua Alexander Calaguas
    15 views1 page
    The petitioners filed an action demanding a 20% Christmas bonus for two years against the respondents. The trial court dismissed the case, finding that a bonus is an act of liberality that the court had no power to compel. The petitioners argued on appeal that they had a cause of action based on a moral or natural obligation of the respondents. The Supreme Court affirmed the dismissal, holding that a natural obligation like a bonus does not grant a right to demand performance, only a right to retain anything voluntarily fulfilled by the obligor, which had not occurred in this case.

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    Original Title

    2 Ansay v. NDC

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    The petitioners filed an action demanding a 20% Christmas bonus for two years against the respondents. The trial court dismissed the case, finding that a bonus is an act of liberality that the court had no power to compel. The petitioners argued on appeal that they had a cause of action based on a moral or natural obligation of the respondents. The Supreme Court affirmed the dismissal, holding that a natural obligation like a bonus does not grant a right to demand performance, only a right to retain anything voluntarily fulfilled by the obligor, which had not occurred in this case.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    15 views1 page

    Philippine Education Co. V CIR and NUL: From A Legal Point of View A Bonus Is

    Uploaded by

    Joshua Alexander Calaguas
    The petitioners filed an action demanding a 20% Christmas bonus for two years against the respondents. The trial court dismissed the case, finding that a bonus is an act of liberality that the court had no power to compel. The petitioners argued on appeal that they had a cause of action based on a moral or natural obligation of the respondents. The Supreme Court affirmed the dismissal, holding that a natural obligation like a bonus does not grant a right to demand performance, only a right to retain anything voluntarily fulfilled by the obligor, which had not occurred in this case.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    2 Ansay v. NDC  Philippine Education Co.

    v CIR and NUL: From a legal point of view a bonus is


    107 Phil 997 not a demandable and enforceable obligation. It is so when it made a part of
    April 29, 1960 the wage or salary compensation
    Calaguas o In this case, the bonus was not made part of the wage or salary
    Topic: Kinds of Obligations as to basis & enforceability compensation
    Petitioners: Primitivo Ansay, etc., et al.
    Respondents: The Board of Directors of the National Development Company, et al. Dispositive: Premises considered, the order appealed from is hereby affirmed,
    Ponente: Paras, C.J. without pronouncement as to costs.

    Doctrine: 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 y reason thereof

    Facts:
     Petitioner-appellants filed against respondent-appellees an action praying for
    20% Christmas bonus for the years 1954 and 1955
     Respondent-appellees filed a motion to dismiss on the ground of lack of cause
    of action
    o The CFI ruled in their favor
    o “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”
    o Basically, the CFI ruled that the claim for bonus was based on moral
    obligation to give and so it had no power to compel its performance
     MR was filed but denied. Hence this appeal
     Petitioner-appellants contend that they have an existing cause of action since
    their claim is based on moral grounds or that it is a natural obligation on the
    part of respondent-appellees to give the bonus

    Issue: Whether petitioner-appellants’ demand for bonus was demandable and


    enforceable?

    Held:
    No, the bonus in this case arises only from a natural obligation
     Natural obligations do not grant a right of action to enforce their performance
    o They are obligations based on equity and natural law, not positive law
    o Nevertheless, if there is voluntary fulfillment by the obligor (debtor),
    then retention of what has been delivered or rendered by reason
    thereof is authorized
     In short, retention can only be authorized if there was
    voluntary performance on the part of the obligor
     In this case, there was no voluntary performance

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