Dear Atty. Kathy,

I am a payroll officer in our company. HR is asking me for proof that several employees were paid their salaries. However, what I only have are payslips, which are accessible by the employees in their respective online account with the company, but these are unsigned. We do not have signed payslips since the employees receive their salaries through their assigned bank accounts. What other proof can I provide, to show that said employees indeed received their salaries?

Adrian

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Dear Adrian,

Preliminarily, as ruled by the Supreme Court, payrolls will only be considered as substantial evidence of payment of salaries when they indicate that the employee has actually received the salaries or monetary benefits; and when they reflect the dates or period covering the money claims.

With regard to the crediting of salaries to the bank payroll accounts of employees, the Court has identified the following three stages: (1) the preparation of payroll by the employer, where the employer is the only actor; (2) the employer’s submission and corresponding receipt by the bank of the payroll or advisory, where the employer and the bank play active roles in the process; and (3) the crediting of the amounts to the employees’ bank accounts, which concerns purely bank operations to which the employer has no control and active participation, but which the employer, as a client of the bank, can reasonably presume that the latter has fulfilled its duty to immediately deposit the amounts to the employees’ bank accounts.

Thus, the minimum requirement for your company to prove payment of the employees’ salaries and other benefits is evidence of the second stage, for example, proof of submission or receipt by the bank of the company’s payroll or advisory. This would be the other proof that you can provide, which would be substantial evidence of payment of the employees’ salaries and monetary benefits.

(Philippine Airlines, Inc. v. Romeo N. Ahmee, et al., G.R. Nos. 221065 and 221164, 7 April 2025)

Atty. Kathy Larios