Short answer. Yes. The general rule is that a contractor who supplies only labour cannot be paid if the work is destroyed before delivery, but the owner's delay in receiving it is a recognised exception. If the owner was already in delay when the work was lost, the contractor may still claim compensation.
What the law says
The contractor who has undertaken to put only his work or skill, cannot claim any compensation if the work should be destroyed before its delivery, unless there has been delay in receiving it
Civil Code, Article 1718 — Loss Where Contractor Furnished Only Labor. Read the full provision →
The starting point: the risk is on the worker
Where a contractor undertakes to supply only his work or skill, the labour, with the materials coming from the owner, the Civil Code places the risk of accidental loss on the worker until the job is delivered. The article says such a contractor cannot claim any compensation if the work should be destroyed before its delivery. So if a finished or half-finished piece is lost before it is handed over, the general position is that the worker absorbs the loss and cannot demand payment for the effort already put in. Delivery is the pivotal moment that shifts that risk.
Why the owner's delay changes the answer
The rule has a built-in exception, and it is the one this question turns on: the worker is barred from claiming unless there has been delay in receiving it. If the work was ready and the owner, without good reason, held off accepting or taking delivery, the law does not let that owner benefit from a loss its own delay helped cause. In that case the risk effectively passes back to the owner, and the worker may still be paid despite the destruction. The exception rewards the worker who did their part on time and puts the consequence of foot-dragging on the party responsible for it.
The article's other exceptions
Delay is not the only way a worker can still recover. The same provision keeps the right to compensation where the destruction was caused by the poor quality of the material, provided this fact was communicated in due time to the owner, so a worker who warns that owner-supplied materials are defective is not made to bear a loss those materials caused. The article also addresses the materials themselves: if the material is lost through a fortuitous event, the contract is extinguished. That ends the arrangement rather than shifting payment, because the thing the parties were working on no longer exists.
What you would need to show
Whether this helps you depends on the facts, and delay is the fact usually in dispute. You would need to show the work was ready for delivery and that the owner's failure to receive it was the reason it was still in the worker's hands when it was lost. Dates, notices offering delivery, and any refusal or postponement by the owner are what carry that argument. Because the outcome hinges on these details, it is worth having the timeline reviewed carefully before either demanding or resisting payment. A lawyer can weigh where the risk had come to rest.