G.R. No. 209535 - Lee vs. Lui Man Chong

Dee C. Chuan & Sons, Inc. (Petitioner) filed a petition seeking an order for authority to hire additional laborers on a temporary basis.
Respondents include the Court of Industrial Relations, the Congress of Labor Organizations (CLO), Kaisahan Ng Mga Manggagawa sa Kahoy sa Pilipinas, and Julian Lomanog with his work-contract laborers.
The case arose during a pending industrial dispute between the petitioner and a labor organization, which had already led to prolonged hearings and a strike.

The petitioner requested permission “to hire about twelve (12) more laborers from time to time and on a temporary basis,” originally stating that the workers could be chosen from either Filipinos or Chinese.
The Court of Industrial Relations granted the application on the condition that “the majority of the laborers to be employed should be native,” effectively favoring Filipino labor over alien (Chinese) labor.
The petitioner, although noting that 75% of its shares were held by Philippine citizens, objected to the condition as a financially and constitutionally restrictive imposition on its right to hire freely, arguing it amounted to discrimination based on nationality.

The petitioner contended that the imposed condition violated the equal protection clause by restricting its liberty to engage employees of any race or nationality.
It further argued that this restriction was not directly affecting its own rights since the petition was aimed at protecting the rights of prospective employees (aliens) who had not come forward to claim redress.
The petitioner questioned the relevance of its capitalization with foreign capital and foreign management, suggesting that such facts were immaterial to the main issue of labor selection preferences.
The context of a lingering labor dispute, coupled with the confrontation between striking employees and management regarding the employment of temporary laborers, underscores the public policy and labor peace considerations inherent in the matter.

The order was justified under Commonwealth Act No. 103, which empowers both the legislature and delegated bodies (such as the Court of Industrial Relations) to regulate labor conditions during industrial disputes.
The court stressed that its intervention was not intended to permanently limit the right of an employer to hire but to serve as an expedient measure to settle the existing industrial dispute and to prevent further conflict.
Both majority and dissenting opinions referenced American jurisprudence (notably Truax vs. Raich and U.S. vs. Wong Kum Ark) to discuss the limitations of judicial intervention in matters of employee selection and non-discrimination.

Whether the condition requiring the majority of newly hired laborers to be Filipino was constitutionally valid under the equal protection clause.
Whether Dee C. Chuan & Sons, Inc. had the legal standing to challenge the condition on behalf of potential alien employees who might be disadvantaged, given that it did not itself suffer direct hardship.

Whether the Court of Industrial Relations exceeded its statutory authority by imposing a hiring condition based on national origin when the petitioner was within its right to hire laborers of any nationality under its application.
Whether the imposition of such a condition represented an intrusion into the employer’s right to freely choose its workforce or was a legitimate exercise of judicial power in light of a pending industrial dispute.