Case Digest (G.R. No. L-21013)
Facts:
The case involves Universal Corn Products, Inc. and its co-petitioners, who are all aliens, as petitioners-appellants against the Rice and Corn Board and its members, who are the respondents-appellees. The events leading to this case began with the promulgation of Resolution No. 10 by the Rice and Corn Board on November 21, 1960, which was based on the authority granted by Section 6 of Republic Act No. 3018. This resolution stated that no person who is not a citizen of the Philippines could be employed in any Filipino-owned establishment engaged in the rice and corn industry, except for technical personnel authorized by the President. Universal Corn Products, Inc., a corporation wholly owned by Filipino citizens, employed over 200 individuals, with the exception of several key positions held by alien employees, including the executive vice-president and sales manager. These alien employees had been with the company prior to the enactment of Republic Act No. 3018 and the issua...
Case Digest (G.R. No. L-21013)
Facts:
Parties Involved:
- Petitioners: Universal Corn Products, Inc. (a Filipino-owned corporation) and its alien employees.
- Respondents: Rice and Corn Board and its members.
Legal Basis:
- Republic Act No. 3018 and Rice and Corn Board Resolution No. 10, which prohibited the employment of non-citizens in the rice and corn industry, except for technical personnel authorized by the President.
Petitioners’ Claim:
- Universal Corn Products, Inc. is a Filipino-owned corporation engaged in the rice and corn industry.
- It employs over 200 Filipinos and a few aliens in key positions (e.g., executive vice-president, comptroller, sales manager).
- These alien employees were hired before the enactment of Republic Act No. 3018 and Resolution No. 10.
Issue Raised:
- Petitioners sought a declaratory relief to challenge the retroactive application of Resolution No. 10, arguing that it would unconstitutionally deprive the alien employees of their livelihood without due process and equal protection of the law.
Respondents’ Defense:
- The Rice and Corn Board argued that the law and resolution were not retroactive but applied prospectively.
- They contended that the employment of aliens in the regulated industry became unlawful upon the passage of Republic Act No. 3018, regardless of when the employment contracts were entered into.
Issue:
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Ruling:
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Ratio:
Prospective Application of Laws:
- The Court reiterated the well-established rule that statutes operate prospectively unless the legislative intent for retroactivity is expressly declared or necessarily implied.
- Republic Act No. 3018 and Resolution No. 10 were enacted to take effect prospectively, and their application to existing employment contracts does not constitute retroactivity.
Police Power and Public Welfare:
- The regulation of employment in the rice and corn industry is a valid exercise of the State’s police power, aimed at promoting public welfare and national security.
- The exclusion of aliens from employment in this industry is justified as a measure to protect the economic interests of Filipino citizens.
No Violation of Constitutional Rights:
- The dismissal of alien employees under the resolution does not violate due process or equal protection, as the law applies uniformly to all similarly situated individuals.
- The Court emphasized that the nationalization of employment is a legitimate policy to enhance the welfare of Filipino citizens and is consistent with constitutional principles.
Precedents Cited:
- The Court relied on prior decisions, such as Montilla v. Augustinian Corp. and Segovia v. Noel, to support the principle of prospective application of laws.
- It also referenced King v. Hernaez to affirm the constitutionality of nationalization measures in employment.
Conclusion:
The Supreme Court upheld the validity of Resolution No. 10 and its application, ruling that it does not operate retroactively and does not violate constitutional rights. The decision underscores the State’s authority to regulate employment in industries critical to national welfare under its police power.