Case Digest (G.R. No. L-43633-34)
Case Digest (G.R. No. L-43633-34)
Facts:
Pablo Arizala, Sergio Maribao, Leonardo Joven, and Felino Bulandus v. Court of Appeals and the People of the Philippines, G.R. Nos. L-43633-34, September 14, 1990, the Supreme Court First Division, Narvasa, J., writing for the Court.Petitioners were supervisory employees of the Government Service Insurance System (GSIS) stationed at its Central Visayas Regional Office. Under the collective bargaining agreement between GSIS and the GSIS Employees Association, a maintenance-of-membership clause required employees who were union members at the agreement’s execution to remain in good standing for its duration. When petitioners, occupying supervisory posts, refused demands to resign from the GSIS Employees Association, separate criminal complaints were filed against them for violating the prohibitions of the Industrial Peace Act (R.A. No. 875) (Crim. Case No. 5275‑R for Arizala and Maribao; Crim. Case No. 4130‑R for Joven and Bulandus).
City Court convictions imposed fines of P500 (with subsidiary imprisonment). The accused appealed to the Court of Appeals (docketed CA‑G.R. Nos. 14724‑CR and 14856‑CR), the appeals were consolidated, and on January 29, 1976 the Court of Appeals affirmed the convictions and denied reconsideration. The petitioners then filed a petition for review on certiorari with the Supreme Court (Rule 45), contending that subsequent constitutional and statutory changes — notably the 1973 Constitution, the Labor Code (P.D. 442), PD 807, Executive Orders 111 and 180, and later amendments (including R.A. 6715) and the 1987 Constitution — altered or removed criminal liability for the acts charged and permitted supervisors to remain in or join certain labor organizations.
The focal question presented to the Court was whether petitioners’ criminal liability under R.A. No. 875 survived these subsequent legal developments or whether repeal/alteration of the penal prohibitions deprived the courts of jurisdiction to punish the conduct charged.
Issues:
- Did subsequent constitutional and statutory changes repeal or otherwise eliminate the criminality of the petitioners’ conduct under R.A. No. 875 so as to deprive the courts of jurisdiction to convict and punish them?
- Under the later legal regime (Labor Code, EO 111, EO 180, and R.A. 6715), were supervisory employees such as the petitioners permitted to remain members of rank‑and‑file labor organizations so that their membership is no longer punishable?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)