G.R. No. 159139 - Information Technology Foundation of the Philippines vs. Commission on Elections

Petitioner Armando Locsin, serving as officer-in-charge of the Talisay-Silay Planters’ Association, was charged and convicted for violating Republic Act No. 679, also known as “The Woman and Child Labor Law.”
The specific offense involved the dismissal of a female employee, Celia Navarosa Banas, which directly resulted in the denial of her maternity leave benefits as provided by the law.

On October 12, 1964, a communication signed by the petitioner was issued, effecting the dismissal of Ms. Banas while she was in her eighth month of pregnancy.
Subsequent to the initial dismissal, the petitioner sent two additional letters—one dated November 5, 1964, and another dated January 5, 1965—refusing to reconsider the termination or to provide the maternity benefits to which Ms. Banas was entitled.

The case was prosecuted under Republic Act No. 679, which mandates maternity leave benefits and imposes liability on the manager or the person acting in that capacity when violations occur.
At trial, evidence included the dismissal letter and the two follow-up communications, corroborating that Ms. Banas did not receive the statutory maternity leave benefits.
An alleged board resolution dated October 2, 1964 was introduced by the petitioner to claim that the dismissal was authorized by the Board of Directors, though this resolution failed to appear in the dismissal correspondence or in the findings of the Bureau of Labor.

The Trial Court convicted the petitioner and sentenced him to pay a fine of P3,000.00 with subsidiary imprisonment (imprisonment imposed at the rate of One (1) day for every Eight (8) Pesos, not exceeding six months) along with an order to pay Ms. Banas P357.40 for her lost maternity benefits.
The Court of Appeals affirmed this verdict, with modifications pertaining to the conditions of subsidiary imprisonment.
The petitioner then elevated the case to the Supreme Court through an appeal by certiorari, acknowledging that the factual findings of the lower courts were established and final.

Whether the acts constituting the offense, allegedly authorized and directed by the Board of Directors, should instead render the directors liable rather than the petitioner, who was designated as the “chemist-representative.”
Whether the petitioner’s role was merely ministerial in implementing the Board’s decision to terminate Ms. Banas’ employment, thus absolving him of personal liability.

Whether Section 12 of Republic Act No. 679 is ambiguous, and if such ambiguity should be resolved in favor of the petitioner, potentially limiting his liability.
How the statutory language regarding the liability of the “manager or, in his default, the person acting as such” applies to the petitioner given his actual functions within the association.

The credibility and authenticity of the purported board resolution that allegedly authorized the dismissal.
Whether the absence of any mention of the board resolution in the dismissal letter and the subsequent investigation by the Bureau of Labor undermines the petitioner’s defense.