Case Summary (G.R. No. 123924)
Applicable Law
The governing framework for this decision is based on the 1987 Philippine Constitution and involves provisions under Batas Pambansa Blg. 697, particularly Article III, Sections 4 to 6. This legislation governs the selection of representatives from the agricultural labor, industrial labor, and youth sectors for certain legislative bodies.
Petitioners' Arguments
The petitioners contest the constitutionality of Section 6 of Article III of Batas Pambansa Blg. 697 on two fronts: they claim unlawful delegation of legislative power and denial of equal protection under the law. They assert that their large membership, representing over one million workers in various sectors, entitles them to participate in the nomination process for sectoral representatives. They also contend that there has been a lack of proper communication from the respondent regarding the nomination process.
Respondent's Position
In his comments, Solicitor General Estelito P. Mendoza, acting on behalf of the respondent, highlighted that nominations for sectoral representatives are to be submitted through any format, including resolutions or letters to the President via the Minister of Labor. The respondent denies any failure to include the petitioners in this process, arguing that petitioners had the opportunity to submit nominations but chose not to.
Court's Ruling on Delegation of Legislative Power
The Court found that the petitioners' claims regarding unlawful delegation of legislative power lack merit. The authority to appoint representatives falls within the executive power of the President, which has been consistently affirmed in prior jurisprudence. The Minister of Labor, as an agent of the President, plays a facilitating role in this process rather than acting as a legislative authority.
Implications of Non-Delegation Doctrine
The Court further elaborated that the rigid non-delegation doctrine has been relaxed. The separation of powers principle allows for greater flexibility, particularly when the legislation in question is designed to address significant social and economic concerns. The relationship between the executive and legislative branches supports a more collaborative approach to governance, making the execution of policies and laws more efficient.
Examination of Equal Protection Claim
The petitioners' assertion of denial of equal protection was also dismissed. The Court noted that Article III, Section 6 of Batas Pambansa Blg. 697 outlines procedural standards for the selection of sectoral representatives that apply uniformly to all relevant organizations and aggroupments. Thus, the argument for favoritism or discrimination is unfounded.
Accountability of Petitioners
The Court emphasized that any failure
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Background of the Case
- The case was heard by the Supreme Court of the Philippines, under G.R. No. 67573, on June 19, 1985.
- Petitioners consisted of Trade Unions of the Philippines and Allied Services (TUPAS-WFTU) and the National Federation of Labor Unions (NAFLU-KMU), representing various labor organizations.
- They challenged the constitutionality of Section 6 of Article III of Batas Pambansa Blg. 697, which governs the selection of sectoral representatives from various labor sectors.
Legal Provisions Involved
- Batas Pambansa Blg. 697 outlines the representation of three sectors: youth, agricultural labor, and industrial labor, with a specific selection process for representatives.
- The law stipulates that sectoral representatives are to be appointed by the President from nominees submitted by recognized labor organizations.
Issues Raised by Petitioners
- Petitioners contended that:
- There was an unlawful delegation of legislative power to the President regarding the appointment process.
- They were denied equal protection under the law, as their members were not adequately represented in the nomination process.
Arguments Presented
- Petitioners argued that their members, representing over one million workers, should have the right to nominate representatives as stipulated by the law.
- They claimed that the process