Case Digest (G.R. No. L-16017)
Case Digest (G.R. No. L-16017)
Facts:
Philippine Tobacco Flue-Curing & Redrying Corporation v. Manuel Sabugo, Fructuoso Alban, and Pedro A. De Leon, G.R. No. L-16017, August 31, 1961, the Supreme Court En Banc, Reyes, J.B.L., J., writing for the Court.The dispute began when Manuel Sabugo filed a complaint with Regional Office No. 1, Department of Labor, claiming unpaid overtime compensation for work allegedly performed in excess of eight hours daily from November 1951 to September 30, 1958, against his employer, Philippine Tobacco Flue-Curing & Redrying Corporation. The regional office officials involved were Fructuoso Alban, Chief of the Labor Relations Section, and Pedro A. De Leon, Hearing Officer.
Contending that Reorganization Plan No. 20A was null and void because it improperly conferred judicial power on administrative regional offices, the corporation filed in the Court of First Instance of Quezon City a petition for prohibition with a prayer for a preliminary injunction to restrain Alban and De Leon from hearing Sabugo’s complaint. A writ of preliminary injunction issued as prayed.
After answers were filed and issues joined, the trial court rendered judgment on the pleadings dated July 2, 1959, sustaining the employer’s petition and issuing a writ of prohibition. The trial court rested its decision on two grounds: (a) that the grant of jurisdiction to regional offices to hear certain money claims under Section 25 of Reorganization Plan No. 20A constituted an undue delegation of judicial power; and (b) that Plan 20A was a nullity because it did not satisfy constitutional requirements for enacting laws. From that judgment the defendants and Sabugo appealed to the Supreme Court.
The appeal presented questions identical to those raised in several contemporaneous cases testing the validity of Reorganization Plan No. 20A and the authority of the Government Survey and Reorganization Commission under Republic Act No. 997, as amended by Republic Act No. 1241. The Supreme Court considered the present appeal together with the reasoning developed in its recent decisions addressing the same plan and statutory scheme.
Issues:
- Does the conferment upon regional offices of the Department of Labor of original jurisdiction over certain money claims under Section 25 of Reorganization Plan No. 20A constitute an undue delegation of judicial power?
- Did Reorganization Plan No. 20A become valid law by non-action of Congress under Section 6(a) of Republic Act No. 997?
- If the conferment of jurisdiction is invalid, may the regional offices issue writs of execution to enforce their decisions?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)