Philippine Association of Free Labor Unions v. Tabigne
REITERATIONFacts
The Antecedents: An administrative case was filed by the Philippine Association of Free Labor Unions (PAFLU) against Honorable Emiliano C. Tabigne, et al. Procedural History: The case was referred for investigation to Mr. Justice Mojica of the Court of Appeals. The Petition: Respondent filed an urgent motion praying for an additional period of five (5) days from October 21, 1967, within which to file his memorandum.
Issue(s)
Whether the respondent is entitled to an extension of time to file his memorandum. Whether the motion for extension should be acted upon by the Supreme Court or the investigating Justice.
Ruling
The Court referred the motion for extension of time to file a memorandum to the investigating Justice of the Court of Appeals for action. It further directed that all similar applications and/or motions filed henceforth be forwarded to the Investigator until his report is submitted to the Supreme Court.
Ratio Decidendi
On the entitlement to an extension of time: The Court did not rule on the merits of the request for extension but instead referred the matter to the investigating Justice. This implies that the initial procedural matters concerning the investigation are within the purview of the Investigator. On the proper forum for acting on motions: The Court explicitly directed that the motion be referred to Mr. Justice Mojica of the Court of Appeals for action. This establishes a procedural protocol for the handling of such motions during the pendency of the investigation. The Court further mandated that "Henceforth and until after the Investigator has submitted his report to this Court, all similar applications and/or motions after being filed shall be forwarded to him for the same purpose." This directive ensures that the investigating body handles preliminary and procedural matters related to the investigation, streamlining the process and allowing the Investigator to manage the case's progression before it reaches the Supreme Court for final adjudication.
Main Doctrine
The Court referred a motion for extension of time to file a memorandum to the investigating Justice of the Court of Appeals for action, and directed that all similar future applications be forwarded to the Investigator until his report is submitted.