G.R. No. 157509 - Automotive Industry Workers Alliance vs. Romulo

Petitioners, composed of ten (10) labor unions (including the Automotive Industry Workers Alliance and its affiliated unions), initiated an original action for certiorari.
They sought to challenge Executive Order No. 185 (dated March 10, 2003), arguing that it was unconstitutional as it allegedly violated the doctrine of separation of powers.
The petitioners maintained that the EO unconstitutionally transferred the administrative supervision over the National Labor Relations Commission (NLRC), its regional branches, and its personnel from the NLRC Chairman to the Secretary of Labor and Employment.
They asserted that the EO reverted the supervisory scheme to an earlier period when the NLRC was effectively operated under the Department of Labor and Employment’s (DOLE) direct supervision.

The NLRC was originally created under Presidential Decree No. 442 (the Labor Code of the Philippines) during Martial Law, as an integral part of DOLE with supervision originally under the Secretary of Labor and Employment.
Under Executive Order No. 292 (the Revised Administrative Code of 1987), the NLRC was reattached to DOLE specifically for policy and program coordination.
Republic Act No. 6715 (amended on March 2, 1989) transferred administrative supervision solely to the NLRC Chairman, thereby limiting DOLE’s supervisory authority.
Executive Order No. 185 was issued by President Gloria Macapagal Arroyo to grant the Secretary of Labor administrative supervision over the NLRC, with the stated objective of expediting case dispositions and preventing graft and corruption.

Argued that EO No. 185 unlawfully amended a provision of law (RA No. 6715) by unilaterally reverting to a pre-amendment supervisory scheme, which is a function reserved for Congress.
Maintained that as labor unions and representatives of an estimated 50,000 workers (and in their capacity as taxpayers), they had a direct and substantial interest in the matter.
Claimed that the executive’s action encroached upon the legislative function by effectively modifying the statutory framework established by law.

Argued that the petition lacked an actual case or controversy as petitioners failed to demonstrate a concrete or personal injury.
Contended that the petitioners—especially in their capacity as labor unions and purported taxpayers—did not have the necessary locus standi.
Noted that, even if individual union members were taxpayers, the EO did not involve additional appropriation of public funds, thereby negating the taxpayer suit rationale.
Asserted that the EO operated strictly within the President’s power of control and supervision over the executive branch, implemented through the doctrine of qualified political agency, and did not affect third-party rights beyond internal administrative matters.

EO No. 185 authorized the Secretary of Labor to oversee administrative functions of the NLRC (including its regional and sub-regional branches) to ensure speedy disposition of pending cases.
It mandated the submission of performance reports, the initiation of measures to curb graft and corruption, and the proper management of internal affairs.
The EO expressly provided that the supervisory power did not extend to the review or modification of the NLRC’s quasi-judicial decisions.
It reiterated that the action was taken under the President’s constitutional power to control and supervise all executive departments, a power indirectly exercised through the Secretary of Labor.

Procedurally, the Government argued the absence of an actual case or controversy and questioned the standing of the petitioners.
Substantively, the contention related to the alleged unauthorized exercise of executive power that encroached upon legislative authority.

The petition thus encapsulated concerns regarding the limits of executive power, legislative authority to amend laws, and the proper threshold for standing in judicial review.

Whether the petition posed an actual case or controversy sufficient to warrant judicial review.
Whether petitioners had the necessary locus standi, considering their roles as labor unions and purported taxpayers, to challenge EO No. 185.

Whether EO No. 185 is unconstitutional for allegedly encroaching upon the legislative function by effectively amending the supervisory structure established by Republic Act No. 6715.
Whether the transfer of administrative supervision over the NLRC from the NLRC Chairman to the Secretary of Labor violates the constitutional doctrine of separation of powers.
Whether the exercise of the President’s power of control and supervision (via qualified political agency) legally permits such internal administrative rearrangements within the executive branch.