GR L 25316; (February, 1979) (Digest)
G.R. No. L-25316 February 28, 1979
KAPISANAN NG MGA MANGGAGAWA SA MANILA RAILROAD COMPANY CREDIT UNION, INC., petitioner-appellant, vs. MANILA RAILROAD COMPANY, respondent-appellee.
FACTS
Petitioner Kapisanan ng mga Manggagawa sa Manila Railroad Company Credit Union, Inc. filed a mandamus petition to compel respondent Manila Railroad Company to prioritize the deduction of its members’ loan obligations from their salaries over other deductions. The petitioner relied on Section 62 of Republic Act No. 2023 , which authorizes a cooperative member to execute an agreement for salary deductions and obligates the employer, upon written request, to make such deductions and remit them to the cooperative. The lower court dismissed the petition.
The petitioner argued that this statutory provision granted its loans first priority in payroll deductions. The respondent company, however, had issued internal documents establishing a specific order of priority for various deductions from employee salaries. The lower court found nothing in the cited law that expressly accorded first priority to credit union obligations, ruling that the law merely compels the employer to act as a collecting agent but does not alter the hierarchy of credits.
ISSUE
Whether Section 62 of Republic Act No. 2023 grants obligations payable to a credit union first priority in the order of salary deductions by the employer.
RULING
No. The Supreme Court affirmed the dismissal of the mandamus petition. The provision of law is clear and unambiguous; it only creates a mechanism authorizing salary deductions and imposes a duty on the employer to effect them upon a member’s agreement and the union’s request. There is no textual basis in Section 62 to support the claim of first priority. The Court emphasized that where the law speaks unequivocally, the judiciary must simply apply it and cannot read into it an intent not expressed. To interpret the law as granting first priority would be to legislate, which is not a judicial function.
Consequently, mandamus does not lie. The writ requires a clear legal right in the petitioner and a correlative duty in the respondent. Since the very law invoked fails to establish the asserted right of first priority, the petitioner had no clear legal right to enforce. The Court reiterated the well-settled doctrine that mandamus is only proper to enforce specific, clear, and certain legal rights, and it never issues in doubtful cases. The respondent company’s act of setting an order of priority for deductions was not a violation of the law but an implementation thereof.