Case Digest: Asia Bed Factory vs National Bed Worker’s Union, et. al., G.R. No. L-9126

Asia Bed Factory vs National Bed Worker’s Union, et. al., GR No. L-9126, January 31, 1957

Subject: Obligations and Contracts

FACTS

On June 2, 1953, the petitioner Asia Bed Factory and respondent labor union entered into a collective bargaining agreement which contained, among other things, that “the employees shall be provided with work on Sundays at time and one-half; and that in the event that no work on Sundays is available through no fault of the employees, they shall be entitled to payment of the equivalent of their wages as if they had performed referred for that day.”

The petitioner faithfully complied with the terms of the above clause until it was forced to suspend its business on Sundays in obedience to the provisions of Republic Act No. 946, known as the Blue Sunday Law, which took effect on September 8, 1953, prohibiting the opening of any commercial, industrial or agricultural enterprise on Sundays.

ISSUE

Whether or not the petitioners are still obligated to pay the employees compensation during Sundays even no work was rendered, pursuant to the CBA and notwithstanding the Blue Sunday Law

RULING

No. 

Under Art. 1266 of the NCC, the debtor in obligations to do shall also be released when the prestation becomes legally or physically impossible without the fault of the obligor.

This case is an example of legal impossibility as contemplated in Art 1267, whereby the obligation of the petitioner to pay employees on Sundays is extinguished by virtue of a legislation prohibiting the work on Sundays.  It is true the agreement provides for the payment of wages on Sundays if no work is made available on those days through no fault of the employees. But the fact is that the agreement does give the employer the right to provide work on Sundays. And it would seem the height of injustice to deprive the employer of this right without, at the same time, relieving him of the obligation to pay the employees.

Section 6 of the Blue Sunday Law which says that "it shall be unlawful for any employer to reduce the compensation of any of his employees or laborers by reason of the provisions of this Act" does not militate against this view. There is here no attempt on the part of the employer to reduce the compensation of his employees. It is the law itself which in effect reduces that compensation by depriving the employees of work on Sundays, thus preventing them from earning the wages stipulated in the bargaining agreement.