Manila, June 20 -- The Supreme Court has ruled that to prove salary payment through banks, employers must show the payroll was submitted to and received by the bank.

This ruling was contained in a 36-page decision of the SC First Division on April 5 when sent back to the National Labor Relations Commission (NLRC) for a case involving the 1998 strike by 49 Philippine Airlines (PAL) pilots, according to a news release Friday.

The ruling, penned by Chief Justice Alexander Gesmundo, affirmed the Court of Appeals ruling that PAL did not sufficiently prove payment of salaries and 13th month pay to its former employees.

"The Payroll Listing and 13th Month Pay Payroll Register presented by PAL were not enough, as they did not provide proof of ...