Quiao v. Abaday
REITERATIONFacts
The Antecedents: Anita Abaday and Juanita Isoy filed claims for underpayment of wage, overtime pay, and separation pay against Chung Quiao alias Bina Tan before the Department of Labor in Cagayan de Oro City. The employer failed to appear, was declared in default, and the hearing officer rendered decisions ordering the employer to pay Anita Abaday P2,042.30 and Juanita Isoy P529.00. Procedural History: The decisions became final and executory, and a writ of execution was issued. The employer then filed a petition for injunction before the Court of First Instance of Misamis Oriental. The court issued a preliminary injunction. The parties submitted a stipulation of facts, and the court a quo rendered a decision declaring the hearing officer's decisions unenforceable and making the injunction permanent. The Petition: The respondents (hearing officer and sheriff) appealed the decision of the Court of First Instance.
Issue(s)
Whether the hearing officer of the Department of Labor has the power and authority to render decisions concerning recovery of wages and salaries. Whether Reorganization Plan No. 20-A, as adopted pursuant to Republic Acts Nos. 997 and 1241, grants regional offices exclusive jurisdiction over money claims arising from violations of labor standards, superseding Republic Act 602.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, declaring the decisions rendered by the hearing officer legally ineffective and unenforceable. The writ of injunction was made permanent.
Ratio Decidendi
On the jurisdiction of the hearing officer: The Court reiterated its established jurisprudence that Reorganization Plan No. 20-A, insofar as it confers judicial powers upon labor officials to pass upon labor claims other than those falling under the Workmen's Compensation Commission, is invalid. This invalidity stems from an unconstitutional delegation of legislative power, which was not contemplated by Republic Act 997, as amended. The failure of Congress to disapprove the plan does not cure this defect, as a measure must be duly passed in accordance with constitutional procedures to be considered a regular statute. Therefore, the hearing officer lacked the legal authority to render the decisions in question. On the effect of Reorganization Plan No. 20-A: The contention that Reorganization Plan No. 20-A supersedes Republic Act 602 and grants exclusive jurisdiction to regional offices over labor money claims was rejected. The Court has consistently held that the said Reorganization Plan is unconstitutional in its delegation of judicial powers to labor officials. Consequently, any provision within the plan that purports to grant such jurisdiction, including Section 25, Article VI, and Section 20, is of no legal effect. The decisions based on this invalid plan cannot be enforced through a writ of execution.
Main Doctrine
Reorganization Plan No. 20-A, insofar as it confers judicial powers upon labor officials to pass upon labor claims other than those that come under the Workmen's Compensation Commission, is invalid because it involves an undue delegation of legislative power not contemplated by Republic Act 997, as amended.