LAW AND DEVELOPMENT

A Paper Presented
in Partial Fulfillment of the Requirements
for the Course Law and Development

The Laboring Labor Force:

An Examination of Art. 1706 Of The New Civil Code

Allowing Employers to Deduct From the Employee’s Wages Debts Due to the Former

Submitted by:

TING, Kathrine T.

11481897

MAY 2018
A Short History
Of the Labor Code of the Philippines

In the late 1800s until the early 1900s, trade unionism rose to 20,000 members in Manila,

and it was burdened with labor unrest – up to the point where management representatives were

threatened with assassination.1 During the 1930s, Pedro Abad Santos, a Katipunero major was

jailed by the Americans during World War II because he organized a Socialist Party which was

composed of peasants and workers in Central Luzon.2 The group fought for agrarian reforms, but

this fight was made through violent means.3 Because of this alarming social unrest rising among

the laborers, then President Manuel L. Quezon adopted a social justice program – among these

were the 8-hour labor law, the extension of workmen’s compensation, minimum wage legislation

and the creation of GSIS.4 Communist movement of the laborers were suppressed though, during

the Japanese occupation as most of them channeled their efforts into Guerilla Resistance.

The Labor Code of the Philippines, or P.D. 44 was enacted on May 1, 1974, by then

President Ferdinand Marcos.5 Its effectivity was however deferred until November 1, 1974,

together with all its amendments and revisions.6 The real intent of this law, however, was to arrest

communist infiltration in the trade union movement.7 Strikes and other concerted activities, which

were the favorite weapons of the communists and other insurgents were banned during the Martial

Law period.8

1 JORGE SIBAL, A CENTURY OF THE PHILIPPINE LABOR MOVEMENT (2004).

2 Id.
3 Id.
4 Id.
5 CESARIO AZUCENA, EVERYONE’S LABOR CODE, (2015).
6 Id.
7 Supra, note 1.
8 Id.
Of the Constitutional Provisions on Labor

Under the 1987 Constitution, it contains a total of five provisions in support of labor.9

Under which, the State affirms labor as a primary social economic force, and has endowed to

protect the rights of workers and promote their welfare,10 by providing representation in

Congress,11 or by giving preference to Filipino labor,12 among others.

However, the most notable is found under Art. XIII, Sec. 3, to wit:

SECTION 3. The State shall afford full protection to labor, local and
overseas, organized and unorganized, and promote full employment
and equality of employment opportunities for all.
It shall guarantee the rights of all workers to self-
organization, collective bargaining and negotiations, and peaceful
concerted activities, including the right to strike in accordance with
law. They shall be entitled to security of tenure, humane
conditions of work, and a living wage. They shall also participate
in policy and decision-making processes affecting their rights and
benefits as may be provided by law.
The State shall promote the principle of shared
responsibility between workers and employers and the preferential
use of voluntary modes in settling disputes, including conciliation,
and shall enforce their mutual compliance therewith to foster
industrial peace.
The State shall regulate the relations between workers and
employers, recognizing the right of labor to its just share in the fruits
of production and the right of enterprises to reasonable returns on
investments, and to expansion and growth. (Emphasis supplied)

9 CONST. (1987), art. II, sec. 15; art. VI, sec. 5(2); art. XII, sec. 12; art. XIII, sec. 3, sec. 7.
10 CONST. (1987), art. II, sec. 18.
11 CONST. (1987), art. VI, sec. 5.
12 CONST. (1987), art. XII, sec. 12.
 The same provision, however, was not similarly worded under the 1973 and 1935

Constitution. Moreover, notable is the fact that both prior Constitutions merely contained one

provision with respect to labor.

In fact, under the 1973 Constitution, it states that:

“The State shall afford protection to labor, promote full employment

and equality in employment, ensure equal work opportunities
regardless of sex, race, or creed, and regulate the relations between
workers and employers. The State shall assure the rights of workers
to self-organization, collective bargaining, security of tenure, and
just and humane conditions of work. The State may provide for
compulsory arbitration”13

While the 1935 Constitution, it merely provided:

“State shall afford protection to labor, especially to working women

and minors, and shall regulate the relations between landowner and
tenant, and between labor and capital in industry and in
agriculture.”14
A clear distinction between the three is the length and elaboration on labor rights. It has

gradually increased since the 1935 Constitution, until the present Constitution. No mention was

made in the prior provisions as to the right of workers to a living wage. A living wage is defined

as a basic income that provides more than mere subsistence, enabling participation in society and

some scope for workers and their families to insure against unforeseen shocks.15 In fact, the

International Labor Organization (ILO) has recognized that decent work and a living wage is

integral to the dignity of labor by ensuring `workers a minimum wage that will provide a

13CONST. (1973), art. II, sec. 9.

14CONST. (1935), art. XIII, sec. 6.
15 JANE PARKER, JAMES ARROWSMITH, RAY FELLS & PETER PROWSE, THE LIVING WAGE: CONCEPTS,

CONTEXTS AND FUTURE CONCERNS, LABOUR & INDUSTRY: A JOURNAL OF THE SOCIAL AND ECONOMIC
RELATIONS OF WORK, (2016).
satisfactory standard of living to them and their families’.16 In 2009, the ILO released a publication,

a first of its kind, leaning towards the ILO’s initiative to provide global trends in wages, and to

improve it.17 Suggesting, in addition, that this issue deserves “more systematic research work”.18

This modest effort by the ILO implies the current trend in both international and local landscape

gearing towards ensuring laborers are given living wages.

In addition, in 1953, the Philippines has ratified the 1949 Convention on the Protection of

Wages.19 It states that wages constitute a “privileged debt” that must be paid in full before ordinary

creditors may establish any claim to a share of the assets.20

It is worthy of mention that the Supreme Court has recognized that there have been changes

in the Constitution.21 For instance, in Echegaray vs. Secretary of Justice, the Court traced the

evolution of its rule-making authority, which, under the 1935 and 1973 Constitutions, had been

priorly subjected to a power-sharing scheme with Congress.22 As it now stands, the 1987

Constitution textually altered the old provisions by deleting the concurrent power of Congress to

amend the rules, thus solidifying in one body the Court's rule-making powers, in line with the

Framers' vision of institutionalizing a "[s]tronger and more independent judiciary."23

In the case of Carpio-Morales vs. Court of Appeals,24 the Supreme Court, abandoned the

Aguinaldo Doctrine or the Condonation Doctrine, which had been applicable since the 1950s, as

16 International Labour Organisation’s Committee of Experts, General Survey of the Reports on the Minimum Wage-Fixing
Machinery, in International Labour Conference, 79th Session, Report III Part 4B (1996).
17 International Labour Organization, Global Wage Report 2008/09: Minimum wages and Collective Bargaining: Towards

Policy Coherence (2009).

18 Id.
19 Protection of Wages Convention, Convention No. 95, (1952).
20 Protection of Wages Convention, Convention No. 95, art. 11, (1952).
21 Carpio Morales v. Court of Appeals, G.R. No. 217126-27, November 10, 2015.
22 Echegaray v. Secretary of Justice, G.R. No. 132601, January 19, 1999.
23 Id.
24 Id.
the same no longer holds water under the current Constitution.25 The Supreme Court explained in

the said case, that the Aguinaldo Doctrine originating from the 1959 case of Pascual vs. Hon.

Provincial Board of Nueva Ecija,26 provides that the re-election of a public official to public office

is deemed as condonation of his past acts for which he may have been liable. 27 Thus, all

administrative cases filed in relation to his prior office is deemed dismissed for having been

condoned by the voting masses. It is important to consider that the Pascual case has been decided

under the 1935 Constitution. Thus, in the 2015 case of Carpio-Morales vs. Court of Appeals,

decided under the present 1987 Constitution, the Supreme Court deemed it apt to abandon said

doctrine. Explaining that “it was a doctrine adopted from one class of US rulings way back in 1959

and thus, out of touch from - and now rendered obsolete by - the current legal regime.”28 The

present constitution has already provided for the accountability of public officers under Art. XI,

Sec. 1, said provision, is evidently, lacking under the 1935 Constitution from which the Pascual

case stemmed.

This shows that previous rules, and laws, having been adopted before 1987, could not have

considered the present landscape and leanings of the present Constitution. Thus, with the changing

policies and adaptations of the Constitution, is a need to revisit the ancient laws and policies of the

country, in order for it to conform and harmonize.

25 Id.
26 Pascual v. Hon. Provincial Board of Nueva Ecija, G.R. No. L-11959, October 31, 1959.
27 Id.
28 Supra, note 19.
Minimum wage versus Living wage

Wages are among the most important conditions of work and a major subject of collective

bargaining.29 As early as 1920s, in the Treaty of Versailles, the term “living wage” was already

mentioned in the preamble. ILO Convention No. 131 provides that lawmakers must take into

consideration the needs of workers and their families, taking into account the general level of

wages in the country, the cost of living, social security benefits, and the relative living standards

of other social groups; and economic factors, including requirements of economic development,

levels of productivity, and the desirability of attaining and maintaining a high level of

employment.30

However, the “concept of a minimum wage level that cannot be abated implies the concept

of a minimum living wage”.31 The statutory minimum wage is the lowest basic wage rate fixed by

law that an employer can pay his workers.32 On the other hand, a living wage is a wage sufficient

to maintain, in the circumstances of each country, an adequate standard of life.33

It is thus evident that a living wage may not necessarily correspond to the prescribed

statutory minimum wage. Currently, a family of five needs an average income of at least Php 8,778

a month to meet basic food and nonfood needs, according to the Philippine Statistics Authority

(PSA).34 The amount is 9.4 percent higher than the Php 8,025 poverty threshold recorded in the

29 Emmanuel Reynaud, The International Labour Organization and the Living Wage: A Historical Perspective, available at
http://ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/---travail/documents/publication/wcms_557250.pdf (last
accessed 4 April 2018).
30 Minimum Wage Fixing Convention, Convention No. 131 (1972).
31 ILO, GENERAL SURVEY: WAGE-FIXING MACHINERY, APPLICATION AND SUPERVISION, (1992).
32 R.A. 6727, IMPLEMENTING RULES AND REGULATIONS, DEFINITION OF TERMS (o).
33 Supra, note 29.
34 Philippine Daily Inquirer, Cost of Living Among Filipinos, available at http://newsinfo.inquirer.net/679897/in-the-know-cost-

of-living-among-filipinos (last accessed 4 April 2018).

first half of 2013.35 Specifically, the daily minimum wage in the National Capital Region (Php481),

the highest in the country, is not even half of the family living wage of Php 1,119.36 The gap

between the minimum wage and the family living wage also continues to widen.37

Labor Rights and Development

Legal empowerment is the process through which the poor become protected and are

enabled to use the law to advance their rights and their interests.38 Creating and sustaining

democratic worker institutions and an international legal regime which will promote a more

equitable distribution of wealth are necessary conditions if economic growth is to result in genuine

human development.39 Workers rights are unique, in a sense that these have a more direct

connection with global trade.40 On a broader level the core labor standards are enabling rights that

support the development of democracy.41

In fact, one of the four pillars of legal empowerment of the poor is to ensure the protection

of labor rights.42 It is regarded as a human right according to a United Nations report43, to wit:

“Labor rights are human rights, and the ability to exercise these
rights in the workplace is prerequisite for workers to enjoy a broad

35 Id.
36 IBON Foundation, Substantially Increase Wages, available at http://ibon.org/2017/01/substantially-increase-wages/, (last
accessed, 4 April 2018).
37 Id.
38 United Nations Commission on Legal Empowerment of the Poor, Making the Law Work For Everyone Volume I, (2008).
39 Jonathan Hiatt and Deborah Greenfield, The Importance of Core Labor Rights in World Development, available at

https://repository.law.umich.edu/cgi/viewcontent.cgi?referer=https://www.google.com.ph/&httpsredir=1&article=1215&conte
xt=mjil, (last accessed, 4 April 2018).
40 Id.
41 Id.
42 Supra, note 24.
43 United Nations, 71st Session of the General Assembly, UN Doc. A/71/385 (2016).
 range of other rights, whether economic, social, cultural, political
or otherwise.”
When governments are unable or unwilling to deliver protection and opportunity for all,

the formal system’s legitimacy and relevance are eroded.44 A vicious circle develops, with the

decay of legal institutions and the growth of makeshift informal arrangements feeding on each

other.45 Effective and inclusive laws, enforced through well-functioning institutions, bring a host

of economic benefits such as greater specialization and division of labor, economies of scale, long-

distance trade, and essential financial functions such as credit and insurance.46 In a study, it is held

that higher wages result to higher income.47 A higher income will thus result to higher consumption

– which helps boost industrial sales.48 In addition to this, it has been stated that higher wages result

to productivity of workers.49

In a study made by the United Nations, giving workers secure labor rights encourages

them, and their employers, to invest in new skills that enhance their productivity.50 By providing

them more bargaining power and consequently higher wages commensurate with their increased

productivity, they are encouraged to work harder, and increase productivity.51 Studies have shown

that paying a living wage leads to increased worker morale, worker health and quality of service.

Paying a living wage also lowers absenteeism, turnover and recruiting and training costs. 52 A living

44 Supra, note 24.

45 Supra, note 24.
46 Supra, note 24.
47 Valentino Piana, Wages, available at http://www.economicswebinstitute.org/glossary/wages.htm (last accessed 22 May

2017).
48 Id.
49 TORBJORN HÆGELAND AND TOR JAKOB KLETTE, DO HIGHER WAGES REFLECT HIGHER PRODUCTIVITY

(1997).
50 Supra, note 24.
51 Supra, note 24.
52 Orange County Living Wage, What are the Benefits of a Living Wage, available at
http://www.orangecountylivingwage.org/benefits (last accessed 22 May 2018).
wage in particular, reverses the trend of the declining monetary value of the minimum wage and

creates an income that more accurately accounts for the cost of living today.53

In fact, it was held that there is a direct relation between increase of sustainable per capita

income increase and economic growth, vis-à-vis continuous technological innovation and

industrial upgrading – which all forms part of modern phenomenon.54 The new structural

economics associates development with the structure of a country’s economy, in particular, the

industrial sector.55 It has a relation to the country’s resources, which essentially determines the

country’s industrial advantage.56 Labor, being one of the country’s largest pool of resources, must,

therefore, be developed and taken care of.

Favor to the Labor Force

In the Philippines, countless cases have been decided re-stating the doctrinal principle

towards the protection of labor.57 As a matter of fact, the New Civil Code58 and the Labor Code,59

provide that in case of doubt and ambiguity, labor contracts, the Labor Code, and its rules must be

construed in favor of labor. In several jurisprudence, the Supreme Court has expanded these

53 Id.
54 JUSTIN YIFU LIN, NEW STRUCTURAL ECONOMICS: A FRAMEWORK FOR RETHINKING DEVELOPMENT (2010).
55 MICHAEL J. TREBILCOCK & MARIANA MOTA PARDO, ADVANCED INTRODUCTION TO LAW AND DEVELOPMENT,

20 (2014).
56 Id.
57 Centro Project v Naluis, G.R. No. 160123, June 17, 2015; Manaya v Alabang Country Club, G.R. No. 168988 June 19,

2007; Uy v Centro Ceramica, G.R. No. 174631 October 19, 2011; Dee Jay’s Inn and Café v Raneses, G.R. No. 191825
October 5, 2016.
58 Civil Code (1949), art. 1702.
59 Labor Code of the Philippines (1974), art. 4.
provisions and has also made the same applicable to evidence.60 In case there doubt between the

evidence of the employer and the employee, the doubt will be resolved in favor of the employee.61

In 1989, two years after the enactment of the present Constitution, R.A. 6727 or the Wage

Rationalization Act was enacted. It had been the policy of said law to rationalize the fixing of

minimum wages and to promote productivity-improvement and gain-sharing measures to ensure a

decent standard of living for the workers and their families.62

Art. 1706, New Civil Code

Despite these provisions gearing towards the protection of labor, and ensuring all workers

are provided with a living wage, there are still old provisions remaining that are not as consistent.

Under the Labor Code, an employer is prohibited from limiting or interfering with the

disposal of the employees’ wages,63 moreover, an employer is likewise prohibited from deducting

from the same, as a general rule.64 There are exceptions – in case of payment of insurance

premiums, and payment of union dues – provided, in both cases, there is consent by the

employee.65 Other exceptions are, for income tax (withholding tax) under the National Internal

Revenue Code; or if such deduction is ordered by the court; premiums for SSS, Philhealth or Pag-

60 South East International Rattan Inc., v. Coming, G.R. No. 186621 March 12, 2014; Masing and Sons Development v.
Rogelio, G.R. No. 161787, April 27, 2011; Dealco Farms v National Labor Relations Commission, G.R. No.153192, January
30, 2009.
61 Id.
62 Rep. Act 6727 (1989), sec. 2.
63 Labor Code of the Philippines (1974), as amended, Art. 112.
64 Labor Code of the Philippines (1974), as amended, Art. 113.
60 Id.
IBIG. Aside from the Labor Code, the New Civil Code allows deduction, automatically, by the

employer for an employee’s debt due to the former under Art. 1706,66 specifically, it provides:

Art. 1706. Withholding of the wages, except for a debt due, shall not

be made by the employer.67

Compared to the other provisions where a deduction from the employees’ wages is

allowed, it is noteworthy that deductions are only allowed when the law provides – usually for the

benefit of the employee, to protect the government (in case of taxes), or a judgement-creditor (in

case of a court order), or when there is consent, implied or express from the employee concerned.

Art. 1706 of the New Civil Code allowing an automatic deduction is neither with the consent of

the employee, nor is it for the benefit of the employee.

The New Civil Code became effective June 18, 1950. It is heavily influenced by the

Spanish Codigo Civil. As a short history, Spanish colonial government is known to have practiced

slavery.68 At that time, the Filipino slaves were allowed to be sold to European mercenaries, settlers

and even the Roman Church.69 Because of this, the Spanish Codigo Civil, and its successor, the

New Civil Code, are not as keen to protect the labor force as compared to the present Constitution,

and other international conventions.

The allowance of the deduction was sanctioned by Art. 1706, as explained in the case of

Deoferio vs. Intel Technology70, because of legal compensation – which can take place between

66 Civil Code (1949), Art. 1706.

67 Id.
68 WILLIAM HENRY SCOTT, SLAVERY IN THE SPANISH PHILIPPINES, 78 (1991).
69 Id.
70 Deoferio v. Intel Technology, G.R. No. 202996, June 18, 2014.
two persons who are creditors and debtors of each other.71 However, it is important to consider

that the landscape of the “legal regime”72 of the present times are already different.

Legal Compensation and Deduction from Wages of Debt

It can be argued, on the other hand, that there could be a valid automatic deduction

consistent with legal compensation. Compensation is defined as a mode of extinguishing

obligations whereby two persons in their capacity as principals are mutual debtors and creditors of

each other with respect to equally liquidated and demandable obligations to which no retention or

controversy has been timely commenced and communicated by third parties.73

Under the New Civil Code, the requisites for a valid legal compensation are: first, that each

one of the obligors be bound principally, and that he be at the same time a principal creditor of the

other; second, both debts consist in a sum of money, or if the things due are consumable, they be

of the same kind, and also of the same quality if the latter has been stated; third, that the two debts

be due; fourth, that they be liquidated and demandable; and fifth, that over neither of them there

be any retention or controversy, commenced by third persons and communicated in due time to

the debtor.74

Although all other elements may be present, the second element, that both debts consists

in sum of money, may not be accurate. Wages, are not ordinary debts by an employer to an

employee. The nature of wages are different. They are a part of employment contracts which are

71 Cebu People’s Multi-Purpose Cooperative v. Carbonilla, G.R. No. 212070, January 27, 2016.
72 Carpio-Morales v Court of Appeals, G.R. No. 217126-27, November 10, 2015.
73 Union Bank of the Philippines v Development Bank of the Philippines, G.R. No. 191555, January 20, 2014.
74 Civil Code (1949), art. 1279.
imbued with public interest.75 Moreover, under the Protection of Wages Convention, ratified by the

Philippines, wages are considered as “privileged debts”, which must be paid in full before ordinary claims

may be made.76 The supremacy of the law over the nomenclature of the contract and the stipulations

contained therein is to bring to life the policy enshrined in the Constitution to "afford full protection

to labor."77 Labor contracts, being imbued with public interest, are placed on a higher plane than

ordinary contracts and are subject to the police power of the State.78

Given this, it is but proper that employees’ wages being part of an employment contract –

whether written or oral, be not given the same weight as ordinary contracts. The ordinary

provisions of law should not be made applicable.

Furthermore, ordinary provisions governing obligations and contracts, must yield to the

Constitutional provision guaranteeing the laborers’ right to a living wage. It is elementary that the

Constitution is the highest law of the land.79 In case of conflict between the Constitution and a

statute, the Constitution always prevails because the Constitution is the basic law to which all other

laws must conform to. The duty of the Court is to uphold the Constitution and to declare void all

laws that do not conform to it.80 Aside from Art. 1706 of the New Civil Code, the provisions of

law that allow deduction from the laborer’s wages is with for the benefit of the benefit of the

employee such as for SSS, Philhealth, or PAG-IBIG, to protect the government (in case of taxes),

or a judgement-creditor (in case of a court order), or when there is consent, implied or express

from the employee concerned.

75 Begino, Del Valle, Avila-Lorin, Sumayao v. ABS-CBN Corporation, G.R. No. 199166, April 2, 2015.
76 Supra, note 20.
77 Leyte Geothermal Power Progressive Employees Union – ALU – TUCP v. Philippine National Oil Company – Energy

Development Corporation, G.R. No. 170351, May 30, 2011.

78 GMA Network v. Pabriga, G.R. No. 176419, November 27, 2013.
79 Sabio v. Gordon, 504 SCRA 704 (2006).
80 Tawang Multi-Purpose Cooperative v. La Trinidad Water District, G.R. No. 166471, March 22, 2011.
The Employer is Given Ample Protection

The employer, who is unable to automatically deduct from the employee’s wages is well-

protected under the law, particularly, the Rules on Small Claims Cases81. In cases of debts

contracted by the employee from the employer, their relationship as regards that debt is no longer

that of an employer and employee, but is that of an ordinary debtor and ordinary creditor. Thus,

said claim amply falls under the Rules on Small Claims Cases.

The Rules provide for a summary hearing and non-appearance of lawyers to ensure the

speedy disposition of cases, which includes a contract of loan82. It merely requires the submission

of affidavits, and presentation of witnesses is unnecessary.83most notable is that lawyers are not

allowed to appear,84 and postponement of a hearing is allowed only once.85The claims of the

employer may thus, be speedily addressed by the Rules on Small Claims Cases.

Moreover, there is a distinction between advances made by the employee and the debts the

employee personally owes to the employer. The former, being advances to his wages, are

deductible, while the latter, being merely debts, should not be automatically deductible.

81 Adm. Matter No. 08-8-7-SC (2000).

82 Adm. Matter No. 08-8-7-SC (2000), sec. 4 (a).
83 Adm. Matter No. 08-8-7-SC (2000), sec. 7.
84 Adm. Matter No. 08-8-7-SC (2000), sec. 17.
85 Adm. Matter No. 08-8-7-SC (2000), sec. 19.
Conclusion

The New Civil Code became effective in 1950, and the economic and legal landscapes now

have changed. As explained in the case of Carpio-Morales, the Supreme Court has recognized that

the 1987 Constitution has changed several principles. Among those, are the accountability of

public officers,86 solidifying the power of the Supreme Court to make rules, and disallowing

Congress from intervening in such,87 and as discussed, the 1987 Constitutional provision on

protection to labor under Art. XIII, Sec. 3.

The Supreme Court, the Legislature in the enactment of laws, and the international

community in general, is more vigilant for the protection of the labor force; laws, treatises and

conventions have been formulated favoring the laborers88, thus, the provision under the Civil Code

allowing an automatic deduction from the wages of the employees debts, musts be re-examined.

It is not accurate to state that the impugned New Civil Code provision is void or

unconstitutional. However, considering the principles both international law and local laws are

gearing towards, it is more accurate to say that said provision under the New Civil Code providing

for automatic deduction, is at most, obsolete. There is a need to amend the law, as the Supreme

Court has no power to amend it, or rule against it on the ground that it is obsolete.

A possible amendment could be to amend Art. 1706 of the New Civil Code to be worded

as follows:

86 CONST. (1987), art. XI, sec. 1.

87 Supra, note 20.
88 Forced Labor Convention, Convention No. C029 (1930); Freedom of Association and Protection of the Right to Organize

Convention No. C087 (1948); Right to Organize and Collective Bargaining Convention, Convention No. C098 (1949); Equal
Renumeration Convention, Convention No. C100 (1951); Discrimination Convention, Convention No. C111 (1958); Minimum
Age Convention, Convention No. C138 (1973); Protection of Wages Convention, Convention of 1949 (1949).
 “Art. 1706. Withholding of the wages, subject to existing laws, shall
not be made by the employer.”

The existing laws refer to the National Internal Review Code, on the withholding of taxes,89

the SSS Law90, the GSIS Law91, the Philhealth Law92, PAG-IBIG Law93, and those provided by

the Labor Code such as, when the employee consents or for union dues.94

As a final note,

As labor creates the wealth of the country, we demand the passage

of such laws as may be necessary to protect it in all its rights."95

89 National Internal Revenue Code (1997), as amended, Sec. 58.

90 Social Security Law, R.A. No. 8282 (1997).
91 The Government Service Insurance System Act of 1997, R.A. No. 8291 (1997).
92 National Health Insurance Act of 2013, R.A. No. 10606 (2013).
93 Home Development Mutual Fund Law of 1980, P.D. No. 1752 (1980).
94 Supra, note 59.
95 John Peter Altgeld.