CASE 14: People v. Vera Reyes (G.R. No. L-45748, April 5, 1939)

Imprisonment for Debt Clause (Article III, Section 1(12), 1935 Constitution)

No person shall be imprisoned for debt, but the Court ruled that non-payment of wages with ability to pay constitutes fraud, which is a punishable offense.

Police Power of the State

The government has the authority to enact laws ensuring laborers receive their wages on time, protecting workers from financial hardship and exploitation.

Act No. 2549, as Amended by Act No. 3958

A law penalizing employers who unjustifiably refuse to pay wages despite having the means to do so. The Court upheld its validity.

Fraud as an Exception to the No Imprisonment for Debt Rule

A debt incurred through fraud or bad faith, such as deliberately withholding wages despite ability to pay, is not protected under the constitutional prohibition against imprisonment for debt.

Social Justice and Labor Protection (Article II, 1935 Constitution)

The law was enacted to prevent labor exploitation and ensure fair wages, consistent with social justice principles.

Criminal Liability for Unjustified Non-Payment of Wages

An employer who refuses to pay wages when financially capable commits an offense similar to estafa (fraud), warranting penal sanctions.

Employer’s Defense Against Wage Non-Payment Cases

Employers can avoid liability if they satisfactorily prove that payment was impossible due to valid reasons beyond their control.

State’s Role in Labor Protection

Without laws penalizing wage withholding, laborers earning meager wages would be forced into costly civil litigation to recover their earnings, exacerbating financial hardship.