Trade Unions of the Philippines and Allied Services v. Ople
REITERATIONFacts
The Antecedents: Petitioners, representing various labor unions and affiliates, assailed the constitutionality of Section 6 of Article III of Batas Pambansa Blg. 697 (BP 697), which governs the selection of sectoral representatives to the Batasang Pambansa. Procedural History: Petitioners filed a prohibition and mandamus proceeding before the Supreme Court. The Petition: Petitioners argued that BP 697 unlawfully delegated legislative power and denied them equal protection, as their members and affiliates, representing over one million workers, were entitled to nominate or participate in the choice of nominees for their sectors. They claimed the respondent Minister of Labor and Employment failed to inform the members of the industrial labor sector and refused to accredit them. Respondent Minister Ople, through the Solicitor General, commented that nominations could be submitted in various forms, and thirteen labor organizations had submitted nominees. Petitioners, however, instead of submitting nominations, sent a letter questioning the constitutionality of the law and the implementation procedures.
Issue(s)
Whether Section 6 of Article III of Batas Pambansa Blg. 697 constitutes an unlawful delegation of legislative power. Whether the selection process for sectoral representatives under Batas Pambansa Blg. 697 denies petitioners equal protection.
Ruling
The petition is dismissed for lack of merit. The Supreme Court ruled that the selection of sectoral representatives under Batas Pambansa Blg. 697 is constitutional.
Ratio Decidendi
On the issue of unlawful delegation of legislative power: The Court held that the power involved is the President's power of appointment, which is intrinsically an executive act involving discretion, not legislative power. The Court cited Concepcion v. Paredes to emphasize the broad authority of the President in appointments. Furthermore, the Court noted that the doctrine on non-delegation of legislative power has become more flexible, especially under the amended Constitution which fosters closer ties between the executive and legislative branches. The Court reiterated the principle from Edu v. Ericta that legislative power is not unduly delegated if the statute is complete in its terms and provisions, and a standard is provided to guide the delegate. The Court found that Batas Pambansa Blg. 697 provides clear standards for the selection of sectoral representatives, including the extent of membership, responsiveness to sector aspirations, militancy, consistency in promoting welfare, and observance of the rule of law. These standards define the legislative policy and boundaries for the implementing agencies. On the issue of denial of equal protection: The Court found the assertion of denial of equal protection to be untenable. The Court emphasized that the law treats similarly situated organizations alike, and there is no discrimination or hostility against any group. The Court pointed out that petitioners failed to submit their nominations, despite the law allowing nominations through simple letters coursed through the respondent Minister. The Solicitor General's comment indicated that petitioners, by sending a letter questioning the law instead of submitting nominations, were responsible for their disadvantageous position. The Court concluded that the law cannot be declared unconstitutional on the ground that petitioners, by their own actions, were not able to submit nominees.
Main Doctrine
The selection of sectoral representatives under Batas Pambansa Blg. 697 does not constitute an unlawful delegation of legislative power, as the President's power of appointment is intrinsically executive, and the law provides sufficient standards for the selection process. Furthermore, the process does not deny equal protection as it treats similarly situated organizations alike and petitioners failed to submit nominations, thus contributing to their disadvantage.