Chartered Bank of India v. Dionisio Constantino

Summary

112 employees of Pananbutan Lumber & Plantation Company prevented Chartered Bank from exporting lumber, claiming retention lien for unpaid wages totaling P30,495.91. The bank had purchased the lumber from the company but employees blocked exportation to secure payment. The Supreme Court affirmed that salaried employees cannot invoke Civil Code Article 1600's retention right, which applies only to artisans doing specific work on personal property, not employees paid for general services. The Court also held that Article 1922's preferred credit provisions don't apply against a bona fide purchaser. Employees should have pursued legal remedies rather than self-help, and the bank's injunction was proper.