Title
Supreme Court
Admin Supervision Over NLRC by DOLE Secretary
Law
Executive Order No. 185
Decision Date
Mar 10, 2003
Executive Order No. 185 grants the Secretary of Labor the authority to oversee and improve the efficiency of the National Labor Relations Commission (NLRC) in order to expedite the disposition of labor cases and prevent graft and corruption within the agency.

Law Summary

Historical Context of NLRC's Administrative Supervision

  • The National Labor Relations Commission (NLRC) was created under Presidential Decree No. 442 (Labor Code of the Philippines) as part of the Department of Labor and Employment (DOLE).
  • Initially, the Secretary of Labor exercised administrative supervision over the NLRC.
  • Executive Order No. 292 (1987 Revised Administrative Code) attached the NLRC to DOLE for policy and administrative supervision.
  • Republic Act No. 6715 (1989) amended this by limiting DOLE’s role to policy and program coordination; administrative supervision was transferred to the NLRC Chairman.

Constitutional Guarantee for Speedy Case Disposition

  • Section 16, Article III of the Constitution ensures the right to a speedy disposition of cases before judicial, quasi-judicial, and administrative bodies.

Rationale for Reinstating Administrative Supervision by Secretary of Labor

  • Evaluation of NLRC’s performance over five years showed delays in case disposition and issues such as graft and corruption.
  • The Secretary of Labor recommended enhanced administrative supervision to expedite case resolution and institute reform measures for system and personnel improvement.

Authority Granted to Secretary of Labor (Section 1)

  • Enables the Secretary to exercise administrative supervision over NLRC, including all regional and sub-regional branches and personnel (Executive Labor Arbiters and Labor Arbiters).
  • Objectives:
    • Improve disposition rates of pending cases.
    • Prevent graft and corruption.
  • Powers include:
    • General oversight of NLRC operations to ensure expeditious case resolution.
    • Require submission of reports deemed necessary.
    • Conduct management audits, performance evaluations, and inspections.
    • Rectify violations, abuses, and maladministration.
    • Investigate disciplinary matters against NLRC personnel and Presidential appointees.
  • Investigations culminate in reporting findings to the President with recommended penalties or referrals to appropriate agencies (PAGC, Ombudsman, etc.).
  • Does not grant power to review or modify NLRC decisions in their quasi-judicial function.

Reporting Requirements for NLRC (Section 2)

  • NLRC Chairman must submit to the Secretary of Labor within 30 days of this Order:
    • Performance reports and audits for the past five years detailing pending and disposed cases.
    • Detailed Master Plan with timelines to clear case backlog within six months.
    • Complete asset inventory and personnel list including positions and stations.
    • Other information as required by the Secretary.

Rulemaking Authority (Section 3)

  • The Secretary of Labor, in consultation with the NLRC Chairman, is authorized to issue rules and regulations to implement this Order effectively.

Repealing Clause (Section 4)

  • All prior executive issuances, rules, and regulations inconsistent with this Order are repealed, amended, or modified accordingly.

Effectivity (Section 5)

  • The Order takes effect immediately upon publication in the Official Gazette or a newspaper of general circulation.

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