Title
Philippine Association of Free Labor Unions vs. Secretary of Labor
Case
G.R. No. L-22228
Decision Date
Feb 27, 1969
PAFLU and SSSEA challenged the cancellation of SSSEA's registration for non-compliance with financial and officer disclosure requirements, alleging constitutional violations and abuse of discretion. The Supreme Court upheld the Registrar's decision, ruling the requirements reasonable and dismissing the petition for failure to exhaust administrative remedies.
A

Case Digest (G.R. No. 185371)

Facts:

  • Petition and prayers
    • The Philippine Association of Free Labor Unions (PAFLU), the Social Security System Employees Association–PAFLU (SSSEA), its officers and members filed a petition for writs of certiorari and prohibition.
    • They sought to restrain the Secretary of Labor, the Director of Labor Relations, and the Registrar of Labor Organizations from enforcing the cancellation of SSSEA’s registration and from applying Section 23 of Republic Act No. 875; they also prayed for a preliminary injunction.
  • Proceedings before the Registrar of Labor Organizations
    • On September 25, 1963, the Registrar issued a notice of hearing set on October 17, 1963, proposing cancellation of SSSEA’s certificate on grounds of:
      • Failure to submit duly verified financial reports for fiscal years ending September 23, 1961 and September 23, 1962 within 60 days; and
      • Failure to file names, postal addresses, and non-subversive affidavits of officers within 60 days of elections in October 1961 and October 1963, as required by SSSEA’s by-laws and Section 23 of RA 875.
    • SSSEA moved to postpone the hearing to October 21; it was granted but SSSEA did not appear.
    • On October 22, 1963, SSSEA’s Assistant Secretary filed a letter with:
      • A joint non-subversive affidavit of its officers;
      • A list of officers elected April 29, 1963; and
      • A copy of its amended constitution and by-laws.
    • The Registrar held these were not the required documents and, on October 23, 1963, cancelled SSSEA’s Registration Certificate No. 1-1P-169.
    • On October 28, 1963, SSSEA’s president moved for reconsideration and more time to comply; an opposition was filed by a member, and a hearing was held on November 27, 1963.
    • On December 4, 1963, the Registrar ordered SSSEA to submit within 15 days non-subversive affidavits of officers elected January 30, 1962, and names, addresses, and affidavits of officers elected October (1st Sunday), pursuant to Section 23(d).
  • Petition for relief in the Supreme Court
    • On December 16, 1963, PAFLU, SSSEA, Alfredo Fajardo, and other officers and members filed the present petition in the Supreme Court.
    • They argued Section 23 of RA 875:
      • Violates constitutional freedom of assembly and association and the Universal Declaration of Human Rights;
      • Constitutes undue delegation of judicial power;
      • Is repealed by ILO Convention No. 87;
      • Was enforced beyond the 30-day period prescribed;
      • Lacks approval by the Secretary of Labor; and
      • Leaves no plain, speedy, and adequate remedy and causes irreparable injury.
  • Procedural posture
    • No writ of preliminary injunction was issued by the Supreme Court.
    • The motion for reconsideration before the Registrar remained pending.

Issues:

  • Whether Section 23 of Republic Act No. 875 infringes the constitutional freedom of assembly and association.
  • Whether Section 23 constitutes an unconstitutional delegation of judicial power to the Secretary of Labor and Registrar.
  • Whether Section 23 is inconsistent with the Universal Declaration of Human Rights and ILO Convention No. 87.
  • Whether the Registrar acted in excess of jurisdiction and with grave abuse of discretion by issuing the cancellation decision beyond 30 days.
  • Whether petitioners have a plain, speedy, and adequate remedy in the ordinary course of law and have exhausted administrative remedies.
  • Whether the cancellation decision required the Secretary of Labor’s prior approval.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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