Aris (Phil.) Inc. v. National Labor Relations Commission
NEW DOCTRINEFacts
The Antecedents: Private respondents, employees of petitioner Aris (Phil.) Inc., protested hazardous working conditions. After management failed to arrange a grievance conference, they marched to the management's office. Consequently, they were issued memoranda requiring them to explain their conduct, and despite their explanations, they were dismissed for violating company rules and regulations. Procedural History: Private respondents filed a complaint for illegal dismissal. Labor Arbiter Felipe Garduque III rendered a decision on June 22, 1989, ordering petitioner to reinstate the complainants within ten days, with limited backwages for six months for most, except for one complainant. The private respondents filed a Motion for Issuance of a Writ of Execution pursuant to Section 12 of R.A. No. 6715. Petitioner filed an Appeal and an Opposition to the motion for execution, arguing that Section 12 of R.A. No. 6715 could not be applied retroactively to pending cases. The Labor Arbiter issued an Order on October 5, 1989, granting the motion for execution and the issuance of a partial writ of execution for reinstatement, citing Section 2 of the NLRC Interim Rules and Section 17 thereof. The Petition: Petitioner filed a petition for certiorari, assailing the constitutionality of Section 12 of Republic Act No. 6715 (amending Article 223 of the Labor Code) and Section 2 of the NLRC Interim Rules on Appeals, which allow execution pending appeal of reinstatement orders. Petitioner argued that these provisions violate the constitutional guaranty of due process by being oppressive and unreasonable, and that they were retroactively applied to a pending case without express provision for retroactivity.
Issue(s)
Whether Section 12 of Republic Act No. 6715, amending Article 223 of the Labor Code, and its implementing rule (Section 2 of the NLRC Interim Rules) are constitutional. Whether the said provisions can be applied retroactively to cases pending at the time of their effectivity.
Ruling
The petition is dismissed for lack of merit. The Court upheld the constitutionality of Section 12 of Republic Act No. 6715 and Section 2 of the NLRC Interim Rules, finding them to be valid exercises of police power and consistent with the constitutional protection afforded to labor. The Court also found that the provisions, being procedural in nature, could be applied to pending cases.
Ratio Decidendi
On the constitutionality of Section 12 of R.A. No. 6715 and Section 2 of the NLRC Interim Rules: The Court held that the challenged provisions are constitutional and a valid exercise of the State's police power. The immediate execution of reinstatement orders pending appeal is a compassionate policy that vivifies and enhances the constitutional provisions on labor and the working man. The Constitution mandates the State to afford full protection to labor, and this provision serves to protect the dismissed employee from the continuing threat to their survival and that of their family. The Court rejected the petitioner's arguments that the provision is oppressive and unreasonable, stating that such rationalizations are misplaced and conjectural. The right to appeal is a statutory privilege, not a constitutional right, and the law may validly provide limitations or reliefs to the prevailing party, such as execution pending appeal. The Court emphasized that the preservation of life is more vital than the preservation of corporate profits, justifying the exercise of police power. On the retroactive application of the provisions: The Court ruled that the provisions, being procedural or remedial in character, can be given retroactive effect to cases pending at the time of their enactment. Settled jurisprudence holds that procedural laws may be given retroactive effect, and there are no vested rights in rules of procedure. The NLRC Interim Rules, promulgated pursuant to the Labor Code, are procedural and thus can be applied to pending cases. The reference to Section 17 of the NLRC Interim Rules by the Labor Arbiter was deemed unnecessary as the appeal proper was not involved, but even so, the rule itself could be applied retroactively.
Main Doctrine
The amendment introduced by Section 12 of Republic Act No. 6715 to Article 223 of the Labor Code, which allows for the immediate execution of the reinstatement aspect of a Labor Arbiter's decision, is constitutional. This provision is a valid exercise of the State's police power, aimed at protecting the welfare of dismissed employees by ensuring their immediate return to work or payroll, even pending appeal. The law is consistent with the constitutional mandate to afford full protection to labor and promote social justice.