1131 NATIONAL FOOD AUTHORITY vs. MASADA SECURITY AGENCY, INC. FACTS: Respondent MASADA Security Agency, Inc.
, entered into a contractto provide security services to the various offices, warehouses and installations of NFA within the scope of the NFA Region I The Regional Tripartite Wages and Productivity Board issued several wage orders mandating increases in the daily wage rate. Respondent requested NFA for a corresponding upward adjustment in the monthly contract rate consisting of the increases in the daily minimum wage of the security guards as well as the corresponding raise in their overtime pay, holiday pay, 13th month pay, holiday and rest day pay. It also claimed increases in Social Security System (SSS) and Pag-ibig premiums as well as in the administrative costs and margin. NFA, however, granted the request only with respect to the increase in the daily wage by multiplying the amount of the mandated increase by 30 days and denied the same with respect to the adjustments in the other benefits and remunerations computed on the basis of the daily wage. The trial court rendered a decision in favor of respondent holding that NFA is liable to pay the security guards wage related benefits pursuant to RA 6727, because the basis of the computation of said benefits, like overtime pay, holiday pay, SSS and Pag-ibig premium, is the increased minimum wage. It also found NFA liable for the consequential adjustments in administrative costs and margin. NFA claims that its additional liability under the aforecited provision is limited only to the payment of the increment in the statutory minimum wage rate, i.e., the rate for a regular eight (8) hour work day.
ISSUE: WON the satisfaction of NFA s Obligation is limited to the payment of the increased statutory minimum wage rates. YES!
RULING: Based on the foregoing interpretation of Section 6 of RA 6727, the parties may enter into stipulations increasing the liability of the principal. So long as the minimum obligation of the principal, i.e., payment of the increased statutory minimum wage is complied with, the Wage Rationalization Act is not violated. In the instant case, Article IV.4 of the service contract provides: IV.4. In the event of a legislated increase in the minimum wage of security guards and/or in the PADPAO rate, the AGENCY may negotiate for an adjustment in the contract price. Any adjustment shall be applicable only to the increment, based on published and circulated rates and not on mere certification. Par 3 of NFA Memorandum AO-98-03- states: 3. For purposes of wage adjustments, consider only the rate based on the wage Order issued by the Regional Tripartite Wage Productivity Board (RTWPB). Unless otherwise provided in the Wage Order issued by the RTWPB, the wage adjustment shall be limited to the increment in the legislated minimum wage; The parties therefore acknowledged the application to their contract of the wage orders issued by the RTWPB pursuant to RA 6727. There being no assumption by NFA of a greater liability than that mandated by Section 6 of the Act, its obligation is limited to the payment of the increased statutory minimum wage rates which, as admitted by respondent, had already been satisfied by NFA. Under Article 1231 of the Civil Code, one of the modes of extinguishing an obligation is by payment. Having discharged its obligation to respondent, NFA no longer have a duty that will give rise to a correlative legal right of respondent. The latter s complaint for collection of remuneration and benefits other than the increased minimum wage rate, should therefore be dismissed for lack of cause of action.
00. The defendant. the petitioners loss could have been avoided if they had simply exercised due diligence in ascertaining the identity of the person to whom they allegedly made the payments. issued genuine SMC liquidation receipts. claiming that they had already paid the plaintiff in full on four separate occasions. doing business under the name and style "Culaba Store" vs. thus. as evidenced by Temporary Credit Invoice No. A person dealing with an agent is put upon inquiry and must discover upon his peril the authority of the agent. SMC filed an action for collection of a sum of money against them before the RTC The defendant-spouses denied any liability. He appeared to be authorized to accept payments as he showed a list of customers accountabilities and even issued SMC liquidation receipts which looked genuine.
. the defendants presented four (4) Temporary Charge Sales (TCS) Liquidation Receipts Defendant Francisco Culaba testified that he made the foregoing payments to an SMC supervisor who came in an SMC van. NO!
RULING: Payment is a mode of extinguishing an obligation. the payments were purportedly made to a "supervisor" of the private respondent. To substantiate this claim.00.910. In this case. extinguishing the same. Failing this. As they failed to pay despite repeated demands.650. considering that the private respondent vehemently denied that the payments were accepted by it and were made to its authorized representative. SMC submitted a publisher s affidavit9 to prove that the entire booklet of TCSL Receipts bearing Nos. In the instant case. leaving an unpaid balance of P24. 27301-27350 were reported lost by it. Thereafter. and they are bound by its consequences. or his successor-in-interest. 42943.740. then paid to the said supervisor. or any person authorized to receive it. the petitioners cannot claim that they acted in good faith when they made such payments.1131 FRANCISCO CULABA and DEMETRIA CULABA. The petitioners in this case failed to discharge this burden. Article 1240 of the Civil Code provides that payment shall be made to the person in whose favor the obligation has been constituted. who was clad in an SMC uniform and drove an SMC van. Their claim therefor is negated by their negligence. The basis of agency is representation. In the case at bar. and that it caused the publication of the notice of loss in the July 9.00. the most prudent thing the petitioners should have done was to ascertain the identity and authority of the person who collected their payments. COURT OF APPEALS and SAN MIGUEL CORPORATION FACTS: SMC sold beer products on credit to the Culaba spouses in the amount of P28. the Culaba spouses made a partial payment of P3. Being negligent in this regard. and he was. in turn. the petitioners cannot seek relief on the basis of a supposed agency. He was then showed a list of customers accountabilities which included his account. in good faith. 1983 issue of the Daily Express
ISSUE: WON the payment of the petitioners obligation to the private respondent was properly made.