G.R. No. 87211 - Mayor vs. Macaraig

Several special civil actions were consolidated because they involved a common, fundamental issue regarding the constitutionality of Republic Act No. 6715.
The petitioners came from various positions within the National Labor Relations Commission (NLRC), including Labor Arbiters, Commissioners, the Executive Director, and the Deputy Executive Director.
Different petition docket numbers exemplify the diverse origins of the cases:

G.R. No. 87211 – Involving Labor Arbiter Jovencio Ll. Mayor and intervenors Lourdes A. Sales and Ricardo Olairez.
G.R. No. 90044 – Involving Executive Director Pascual Y. Reyes and intervention by Deputy Executive Director Eugenio I. Sagmit, Jr.
G.R. No. 91547 – Involving Commissioners Rosario G. Encarnacion, Daniel M. Lucas, Jr., and Ceferino E. Dulay.
G.R. No. 91730 – Involving Commissioner Conrado Maglaya.
G.R. No. 94518 – Involving Labor Arbiter Rolando D. Gambito.

Republic Act No. 6715, effective March 21, 1989, proposed a significant reorganization of the NLRC.
Section 35 of RA 6715 declared vacant all positions of the Commissioners, Executive Labor Arbiters, and Labor Arbiters, while allowing those not directly affected to remain until successors are appointed.
The theoretical purpose was to “professionalize the higher levels of officialdom” by upgrading qualifications, salaries, and ranks.
The reorganization involved:

Changing the composition and nature of the NLRC by granting it a greater measure of autonomy while attaching it to the Department of Labor and Employment only for program coordination.
Introducing tripartite representation, where members were drawn from the workers, employers, and the public sector.
Altering the allocation of powers between the Commission when sitting en banc and through its divisions with fixed territorial jurisdictions.

Some petitioners, such as Jovencio Ll. Mayor, had been appointed as Labor Arbiters in 1986 and were reappointed in March 1990.
Other petitioners, including intervenors Sales and Olairez, were not among those reappointed and continued facing removal.

Pascual Y. Reyes and Eugenio I. Sagmit, Jr. held the offices of Executive Director and Deputy Executive Director, respectively, and were informed by a Memorandum-Order that their positions had been abolished upon the effectivity of RA 6715.
Several incumbent Commissioners like Encarnacion, Lucas, and Dulay received new appointments under RA 6715, though questions arose about the legality of such reappointments and the absence of proper notice regarding termination.

The positions of Executive Director and Deputy Executive Director were effectively replaced by the designations of Executive Clerk and Deputy Executive Clerks, respectively.
The new terms and qualifications for the roles of Commissioners and Labor Arbiters were set to operate prospectively, yet petitioners argued that the retroactive removal violated their security of tenure.

The essence of the factual background is that RA 6715 declared vacancies in the NLRC by reassigning offices, thus removing incumbent officers without proper cause under the constitutional guarantee of security of tenure.
The petitioners contended that the reorganization, despite its stated purpose for improving professionalism, was executed in a manner that retroactively stripped them of their rights as existing civil servants.

Whether the declaration of vacancies under Section 35 of RA 6715 effectively constituted an abolition of the offices held by the petitioners.
Whether such a declaration violated the constitutional guarantee of security of tenure for civil servants.

Whether the reorganization, even if intended to instill higher standards of professionalism, was implemented with due regard to the rights of incumbents.
The proper balance between the need for administrative restructuring and the protection of established civil service rights.

Whether the imposition of new qualifications and designations could legally affect those who had already met the old requirements for their positions.
Whether such retroactive operation of the law amounted to an impermissible removal of public employees from their offices.