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Ansay et al. v. National Development Company (NDC), G.R. No. L-13667, 29 April 1960.

19 Mar

[PARAS, C.J.]

FACTS: Ansay et al. filed against NDC a complaint praying for a 20% Christmas bonus for the years 1954 and 1955. The trial court dismissed the complaint ratiocinating that a bonus is an act of liberality and the court takes it that it is not within its judicial powers to command respondents to be liberal and that Ansay et al. admitted that NDC is not under legal duty to give such bonus and that the court has no power to compel a party to comply with a moral obligation (Art. 142, New Civil Code.). Ansay et al. appealed and argued that there exists a cause of action in their complaint because their claim rests on moral grounds or what in brief is defined by law as a natural obligation.

ISSUE: Is the grant of Christmas bonus for the years 1954 and 1955 demandable based on natural or moral obligation?

HELD: NO.

Article 1423 of the New Civil Code classifies obligations into civil or natural. “Civil obligations are a right of action to compel their performance. Natural obligations, not being based on positive law but on equity and natural law, do not grant a right of action to enforce their performance, but after voluntary fulfillment by the obligor, they authorize the retention of what has been delivered or rendered by reason thereof”. It is thus readily seen that an element of natural obligation before it can be cognizable by the court is voluntary fulfillment by the obligor. Certainly retention can be ordered but only after there has been voluntary performance. But here there has been no voluntary performance. In fact, the court cannot order the performance.

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