G.R. No. 188372 - Beams Philippine Export Corp. vs. Castillo

Case Summary (G.R. No. 188372)

Applicable Law

The legal foundation of the decisions rests upon the 1987 Constitution of the Philippines and the provisions of Republic Act No. 6715, which reorganizes the NLRC, declaring the positions of its Commissioners, Executive Labor Arbiters, and Labor Arbiters vacant and removing the incumbents upon the appointment of their successors.

Background of the Case

The five civil actions arise from a shared issue—the constitutionality of R.A. No. 6715, effective March 21, 1989. This law declared vacant all positions within the NLRC and stipulated the removal of incumbents once successors were appointed. Multiple petitioners, who had served in various capacities within the NLRC, challenged the validity of their removal.

Specific Cases and Petitions

G.R. No. 87211

Jovencio L. Mayor, appointed as Labor Arbiter in 1986, initially filed for relief fearing he would be removed due to the reorganization. However, he was reappointed on March 8, 1990, rendering his case moot. Intervenors Lourdes A. Sales and Ricardo Olairez were not reappointed and also sought reinstatement.

G.R. No. 90044

Pascual V. Reyes, previously the Executive Director of the NLRC since 1975, and his Deputy, Eugenio L. Sagmit, were separated from service as their positions were deemed abolished under R.A. No. 6715. Reyes contested this, asserting that the termination of services was unconstitutional.

G.R. No. 91547

Petitioners Ceferino E. Dulay, Rosario G. Encarnacion, and Daniel M. Lucas Jr. were appointed as Commissioners in 1986 and challenged the constitutionality of their supposed separation from the NLRC as they were not notified of any termination and held that they were not effectively removed.

G.R. No. 91730

Conrado Maglaya’s removal from his position as a Commissioner was similarly contested based on the claim of unconstitutional separation due to the changes instituted by the new law.

G.R. No. 94518

Rolando D. Gambito faced exclusion from the reappointed list of Labor Arbiters and sought reinstatement, emphasizing the unconstitutionality of his removal.

Fundamental Legal Issues

The central legal question revolves around whether R.A. No. 6715 effectively abolished the petitioners’ offices or simply declared them vacant. The petitioners argued that the statute infringed upon their constitutional rights of security of tenure, which protects civil service employees from arbitrary removal, except for lawful cause.

Analysis of the Law and Constitutional Implications

The Supreme Court, leveraging the principle of security of tenure enshrined in the Constitution, examined the provisions of R.A. No. 6715. The Court determined that while the law aimed to professionalize the NLRC, it did not contain explicit provisions abolishing the petitioners’ positions. The mere declaration of vacancies did not suffice to remove the constitutional protections afforded to the petitioners.

Conclusion and Ruling

The Court ruled in favor of the petitioners, affirming that their removals were unconstitutional. It ordered the reinstatement of th