PRIMITIVO ANSAY, ETC., ET AL., plaintiffs-appellants, vs.

THE BOARD OF DIRECTORS OF THE NATIONAL

DEVELOPMENT COMPANY, ET AL., defendants-appellees.

G.R. No. L-13667 April 29, 1960

EN BANC Appeal

PARAS, C. J.:

Facts:

Petitioners was compelling the National Development Company to give them a Christmas Bonus. But
they also acknowledge that since giving bonus is a moral obligation or natural obligation, respondents
are not under legal duty to give their claimed bonus. The lower court dismissed the action arguing that
giving bonus is an act of liberality, and as moral obligation, it is not enforceable.

Issue:

Whether or not giving a Christmas Bonus is demandable and enforceable

Ruling:

No. Since giving Christmas Bonus is a natural obligation, it is not a demandable and enforceable
obligation. But the Court can order its retention after there has been voluntary performance of giving a
bonus. But here there has been no voluntary performance.

It is also demandable and enforceable when it made a part of the wage or salary compensation.
But even if a bonus is not demandable for not forming part of the wage, salary or compensation of an
employee, the same may nevertheless, be granted on equitable consideration as when it was given in
the past, though withheld in succeeding two years from low salaried employees due to salary increase

Premises considered, the order appealed from is hereby affirmed, without pronouncement as to costs.