Kapisanan ng mga Manggagawa sa Manila Railroad Company Credit Union, Inc. vs. Manila Railroad Company

Section 62 of Republic Act No. 2023 authorizes and compels an employer to deduct from an employee-member's wages the amounts owed to the cooperative credit union and remit them upon written request, but it does not confer first-priority preference on such debts over other salary deductions. Absent a clear legal right, mandamus will not issue.

Petitioner Kapisanan ng mga Manggagawa sa Manila Railroad Company Credit Union, Inc. is the employees' cooperative credit union of respondent Manila Railroad Company. The dispute centers on the interpretation of Section 62 of Republic Act No. 2023, a statute governing cooperatives, which authorizes cooperative members to execute agreements directing their employer to deduct from their wages amounts owed to the cooperative and to remit such deductions. The respondent company had issued internal documents (Exhibit "3" and Exhibit "P") establishing the order of priority for payroll deductions from its employees' salaries, which the petitioner challenged as violating the statute.

Petitioner Kapisanan ng mga Manggagawa sa Manila Railroad Company Credit Union, Inc. is the cooperative credit union of the employees of respondent Manila Railroad Company. Members of the credit union could obtain loans from it, and under Section 62 of Republic Act No. 2023, such members could execute agreements authorizing their employer to deduct from their wages the amounts owed to the cooperative and to remit those amounts to the credit union.

Respondent company issued internal documents designated Exhibit "3" and Exhibit "P," which established an order of priority for payroll deductions from its employees' salaries. Petitioner contended that under Section 62 of Republic Act No. 2023, debts owed by employees to the credit union should enjoy first priority in the matter of deductions from wages and salaries. It accordingly filed a petition for mandamus in the lower court to compel respondent to accord such first-priority treatment to credit union debts.

The lower court dismissed the petition, ruling that nothing in the quoted provisions of Republic Act No. 2023 grants first-priority preference to obligations payable to credit unions. It held that the statute's mandatory character extends only to compelling the employer to make the deduction and remit it to the credit union, not to converting the credit union's credit into a first-priority claim. The court noted that if the legislature had intended to grant first priority, it would have expressly declared so, citing Articles 2241, 2242, and 2244 of the New Civil Code as demonstrating the legislative intent on preference of credits. Respondent agreed with this interpretation, maintaining that its issuance of Exhibits "3" and "P" implemented rather than violated Section 62. Petitioner appealed the dismissal to the Supreme Court.

• Statutory Priority of Credit Union Debts: Petitioner argued that under Section 62 of Republic Act No. 2023, particularly the first two paragraphs, loans granted by the credit union to its members enjoy first priority in payroll deductions from the respondent's employees' wages and salaries.
• Mandamus as Proper Remedy: Petitioner sought a writ of mandamus to compel respondent to recognize and implement such first-priority treatment for credit union debts in its payroll deduction system.

• No Implied Priority in the Statute: Respondent countered that nothing in Section 62 of Republic Act No. 2023 implies that it gives top priority to obligations payable to petitioner, and that respondent, in issuing Exhibits "3" and "P" establishing the order of priority of payment out of employees' salaries, did not violate the statute but rather implemented it.

• Statutory Interpretation: Whether Section 62 of Republic Act No. 2023 grants first-priority preference to debts owed by employees to their cooperative credit union in the matter of payroll deductions from wages and salaries.
• Availability of Mandamus: Whether the writ of mandamus lies to compel the employer to accord first-priority treatment to credit union debts under the statute.

• Statutory Interpretation: No. Section 62 of Republic Act No. 2023 merely authorizes and compels the employer to deduct cooperative debts from wages and remit them upon written request; it does not confer first-priority preference on such debts.
• Availability of Mandamus: No. Mandamus does not lie because petitioner failed to establish a clear legal right to the relief sought, the statute providing no basis for a priority claim.

• Statutory Interpretation: The applicable provision of Republic Act No. 2023 speaks for itself and contains no ambiguity. The statute's effect is to compel the employer to deduct from the salaries or wages of cooperative members the amounts owed to the credit union and to remit such amounts upon written request. Nothing in the language grants first-priority preference to credit union debts. To read a priority into the law would be to write something that does not appear in the text — a function reserved to the legislative branch, not the judiciary. The express provisions of Articles 2241, 2242, and 2244 of the New Civil Code demonstrate the legislative intent regarding preference of credits, and had Congress intended to grant first priority to cooperative debts, it would have so expressly declared. Where the statutory norm speaks unequivocally, courts must apply it as written, as consistently held in Gonzaga vs. Court of Appeals.

• Availability of Mandamus: Mandamus is available only where the petitioner demonstrates a clear legal right to the thing demanded and the defendant has an imperative duty to perform the required act. The writ never issues in doubtful cases; it neither confers powers nor imposes duties but simply commands the exercise of a power already possessed and the performance of a duty already imposed. Because the very law on which petitioner relied fails to supply any basis for a first-priority claim, petitioner was unable to show a clear legal right. The lower court correctly dismissed the petition, and a more rigorous analysis would have prevented the institution of the suit in the first place, as reiterated in J.R.S. Business Corporation vs. Montesa and Province of Pangasinan vs. Reparations Commission.

• Plain Meaning Rule / Verba Legis — Where the statutory norm speaks unequivocally, there is nothing for courts to do except apply it. The law, leaving no doubt as to the scope of its operation, must be obeyed. Courts cannot alter or add to what the legislature has enacted; that function appertains to the legislative branch. Applied here to hold that Section 62 of Republic Act No. 2023, being clear on its face, must be applied as written, without reading into it a first-priority preference that the text does not contain.

• Requisites of Mandamus — Mandamus lies only when the petitioner has a clear, legal right to the thing demanded and it is the imperative duty of the defendant to perform the required act. The writ never issues in doubtful cases; it neither confers powers nor imposes duties but is simply a command to exercise a power already possessed and to perform a duty already imposed. Only specific legal rights that are certain and clear are enforceable by mandamus. Applied here to deny the writ because petitioner failed to establish a clear legal right to first-priority treatment of credit union debts.

• "There is no ambiguity. As thus worded, it was so applied. Petitioner-appellant cannot therefore raise any valid objection. For the lower court to view it otherwise would have been to alter the law. That cannot be done by the judiciary. That is a function that properly appertains to the legislative branch." — This passage articulates the ratio decidendi on statutory interpretation: courts must apply clear statutes as written and cannot judicially amend them to create rights the legislature did not provide.

• "Clearly, then, mandamus does not lie. Petitioner-appellant was unable to show a clear legal right. The very law on which he would base his action fails to supply any basis for this petition." — This states the Court's conclusion on the mandamus issue, tying the denial of the writ to the absence of a clear legal right under the statute relied upon.

• "It is well establish that only specific legal rights are enforceable by mandamus, that the right sought to be enforced must be certain and clear, and that the writ not issue in cases where the right is doubtful." — This quotation, drawn from former Justice Recto's formulation as cited in the decision, provides the canonical statement of the requisites of mandamus relied upon by the Court.

• Gonzaga vs. Court of Appeals, L-27455, June 28, 1973, 61 SCRA 381 — Followed for the principle that where a statute speaks unequivocally, courts must apply it as written and cannot alter the law.
• J.R.S. Business Corporation vs. Montesa, L-23783, April 25, 1968, 23 SCRA 190 — Followed for the doctrine that mandamus requires a clear legal right and an imperative duty, and that the writ never issues in doubtful cases.
• Province of Pangasinan vs. Reparations Commission, L-27448, November 29, 1977, 80 SCRA 376 — Followed as the latest reiteration of the well-settled doctrine on the requisites of mandamus.
• Viuda e Hijos de Crispulo Zamora vs. Wright, 53 Phil. 613 (1929) — Cited within the J.R.S. opinion for the foundational statement that mandamus enforces only duties clear and enjoined by law and requires a clear legal right in the petitioner.

• Section 62, Republic Act No. 2023 (1957) — Authorizes a cooperative member to execute an agreement directing his employer to deduct from his wages amounts owed to the cooperative and to remit such deductions upon written request. Applied to hold that the provision merely compels deduction and remittance but does not grant first-priority preference to credit union debts.
• Articles 2241, 2242, and 2244, New Civil Code — Cited by the lower court as demonstrating the legislative intent on preference of credits, showing that Congress knows how to expressly declare priorities when it intends them.

Barredo, Antonio, Concepcion, Jr., Santos, and Abad Santos, JJ., concurred. Aquino, J., took no part.