Filipro v. Fuentes
REITERATIONFacts
The Antecedents: Thirty-one (31) individuals, alleging employment by petitioners Filipro, Inc. and Hilarion Tantoco Brokerage, Inc. between 1946 and February 17, 1958, filed a claim for separation pay with interest amounting to P14,215.50 with the Department of Labor, Regional Office No. 3. They claimed dismissal without just cause and previous notice. Procedural History: Before the scheduled hearing, petitioners filed a Petition for Prohibition with Preliminary Injunction with the CFI of Manila, asserting that the proceedings before the Department of Labor constituted a judicial function and that respondents F. A. Fuentes and J. Benedicto lacked legal authority. They argued that Republic Act No. 997, as amended by Republic Act No. 1241, under which the respondents purported to derive their powers, merely created a commission to reorganize the executive branch and did not confer judicial or quasi-judicial powers. The CFI of Manila issued a preliminary writ of prohibition on June 12, 1958, ordering respondents to desist from proceeding with the hearing. Respondents contended that Reorganization Plan No. 20-A, specifically Sec. 25, validly delegated original and exclusive jurisdiction over such cases to the regional offices. The Petition: The CFI of Manila rendered judgment on October 20, 1960, concluding that the Regional Offices in the Department of Labor were not legally created and that respondents lacked the authority to hear the complaint. The writ of prohibition was granted. Respondents appealed this decision.
Issue(s)
Whether Section 25 of Reorganization Plan No. 20-A, which grants Regional Offices of the Department of Labor original and exclusive jurisdiction over money claims, is a valid delegation of legislative power.
Ruling
The Supreme Court affirmed the decision of the lower court, holding that the writ of prohibition was correctly granted. The Court ruled that the Regional Offices in the Department of Labor were not legally created with the authority to hear and decide the complaint, and that respondents F. A. Fuentes and J. Benedicto, as Administrator and Hearing Officer, respectively, had no such authority.
Ratio Decidendi
On Issue 1: The Supreme Court held that the provision of Reorganization Plan No. 20-A, particularly Section 25, which grants regional offices original and exclusive jurisdiction over money claims of laborers, is null and void. The Court reasoned that it was never the intention of Congress, in enacting Republic Act (RA) No. 997, to authorize the transfer of powers and jurisdiction from the courts of justice to administrative officials or newly created offices. Applying the rule on non-delegation of legislative power, the Court emphasized that the Legislature cannot delegate its authority to create courts of justice to any other agency of the Government. The Court noted that this issue had been definitively settled in previous jurisprudence, specifically 'Corominas, Jr., et al. v. Labor Standards Commission, et al. (G.R. No. L-14837)', which established that the Reorganization Commission, being an executive body, could not be granted such judicial powers. The Court reiterated that the Commission had no authority to confer judicial or quasi-judicial powers upon the Department of Labor (DOL) where none previously existed. Consequently, the Regional Administrator and Hearing Officer had no authority to receive or hear the complaint for separation pay, and the writ of prohibition was properly issued by the lower court.
Main Doctrine
The provision of Reorganization Plan No. 20-A, particularly Sec. 25, which grants to the regional offices original and exclusive jurisdiction over money claims of laborers, is null and void, said grant having been made without authority by Rep. Act No. 997.