Philippine American Management Co. v. Philippine American Management Employees Assn.
REITERATIONFacts
The Antecedents: Petitioners, Philippine American Management Company, Inc. and Philippine American Life Insurance Company, filed a motion for reconsideration of a previous decision that ruled that the Secretary of Labor could endorse a minimum wage dispute resulting in a strike to the Court of Industrial Relations (CIR), which could then issue a return-to-work order. The respondent labor union, Philippine American Management Employees Association (PAMEA-FFW), had previously filed a motion for reconsideration. Procedural History: The Supreme Court had previously promulgated a decision on January 29, 1973, upholding the CIR's power to issue a return-to-work order in such circumstances. Petitioners filed a motion for reconsideration on March 1, 1973, supplemented by a rejoinder on April 18, 1973. The Petition: Petitioners sought further reconsideration of the Court's earlier decision, primarily arguing that allowing the CIR to issue a return-to-work order would contradict the philosophy of the Industrial Peace Act, which favors free bargaining over compulsory arbitration, and attempting to distinguish the acts of the Secretary of Labor from those attributable to the President.
Issue(s)
Whether the issuance of a return-to-work order by the Court of Industrial Relations in a minimum wage dispute endorsed by the Secretary of Labor is in conflict with the philosophy of the Industrial Peace Act. Whether the act of the Secretary of Labor in endorsing a labor dispute to the Court of Industrial Relations is legally attributable to the President of the Philippines.
Ruling
The motion for reconsideration is denied. The Court reiterated its previous ruling that the Court of Industrial Relations has the power to issue a return-to-work order in minimum wage disputes endorsed by the Secretary of Labor, and that the acts of the Secretary of Labor are legally attributable to the President under the doctrine of qualified political agency.
Ratio Decidendi
On the issue of the Court of Industrial Relations' power to issue a return-to-work order: The Court reiterated that the Industrial Peace Act explicitly continues the jurisdiction of the CIR concerning minimum wage controversies endorsed by the Secretary of Labor. The power exercised is necessarily one of compulsory arbitration. This power is not emasculated by the enactment of the Minimum Wage Law, as there is no implied repeal. The Court emphasized that the minimum wage is a matter beyond the scope of collective bargaining, as legislation on minimum wages is compulsory to assure decent living conditions. Therefore, the argument that the CIR lacks jurisdiction to issue a return-to-work order falls flat. On the issue of attributing the Secretary of Labor's act to the President: The Court reaffirmed the firmly embedded doctrine of qualified political agency, citing Villena v. Secretary of Interior. Under this doctrine, the acts of a department head, performed in the regular course of business and conformably to law, are presumptively the acts of the President. The President is the sole dignitary who could disapprove or reprobate such acts. This principle ensures a single, not plural, Executive, with the President being ultimately responsible for the administration of the Executive Department. The Court noted that this doctrine, though it may elicit apprehension, is a necessary corollary of the American presidential type of government established under the Constitution.
Main Doctrine
The Secretary of Labor, in cases of labor disputes concerning minimum wage that result in a strike, may endorse the matter to the Court of Industrial Relations, which, under its arbitral power, can issue a return-to-work order pending the final resolution of the controversy. The doctrine of qualified political agency attributes the acts of a department head to the President, making the President responsible for such actions.