International Hardwood v. Pañgil Federation of Labor
REITERATIONFacts
The Antecedents: The underlying dispute involved demands by the Pañgil Federation of Labor against the International Hardwood and Veneer Company. Key demands included setting a minimum daily wage of one peso for common laborers, devising a proper wage schedule for all laborers, and establishing a 20% higher wage rate for work in mountain camps compared to town work. Prior to the dispute, the company paid a minimum wage of P0.70 per day regardless of work location. Procedural History: The Secretary of Labor certified an industrial dispute between the company and its employees to the Court of Industrial Relations (CIR) on June 2, 1939. The CIR, through Judge Leopoldo Rovira, issued a decision on September 19, 1939, partially granting demands 2 and 4 by ordering a minimum wage of P1.00 daily for mountain laborers and P0.90 daily for town laborers, with an additional 25% for overtime. The company filed a motion for reconsideration, and subsequently, on November 28, 1939, a motion challenging the CIR's jurisdiction to determine minimum wages in this context, arguing it was an undue delegation of legislative power and violated equal protection. The CIR en banc denied both motions on December 23, 1939, leading to the current petition. The Petition: The International Hardwood and Veneer Company filed a petition for a writ of certiorari seeking to review the CIR's resolution. The core of the petition argues that the CIR lacks the authority under section 4 of Commonwealth Act No. 103 to determine minimum wages for an individual employer in a specific industrial dispute. The petitioner contends that such authority is vested exclusively in the President under section 5 of the same Act, which outlines a process for fixing general minimum wages for industries or localities. The petitioner further asserts that if section 4 is interpreted to grant this power, it constitutes an unconstitutional delegation of legislative power and denies the petitioner equal protection of the laws due to a lack of specific standards.
Issue(s)
Whether the Court of Industrial Relations has the power to determine minimum wages for an individual employer in connection with an industrial dispute under Section 4 of Commonwealth Act No. 103. Whether the grant of such power to the Court of Industrial Relations constitutes an undue delegation of legislative power and violates the equal protection clause of the Constitution.
Ruling
The petition for certiorari is denied. The Court of Industrial Relations has jurisdiction to determine minimum wages in an industrial dispute, and the exercise of this power is constitutional.
Ratio Decidendi
On the jurisdiction of the Court of Industrial Relations to determine minimum wages: The Court held that Section 4 of Commonwealth Act No. 103 empowers the CIR to take cognizance of, arbitrate, and settle any industrial dispute causing or likely to cause a strike or lockout, arising from differences regarding wages. The Court reasoned that a narrow construction, which would require the President to first direct an investigation under Section 5 for general minimum wage fixing, would render nugatory the plenary powers conferred upon the CIR to settle disputes and frustrate the law's objective of effective government intervention to prevent non-pacific methods. The Court emphasized that the intention of the National Assembly should be effectuated, and the Act should be construed to achieve this result, allowing the CIR to settle disputes concerning wages, even if it involves setting minimum wages for an individual employer within the context of a specific dispute. On the constitutionality of the grant of power: The Court found no undue delegation of legislative power nor violation of the equal protection clause. It cited Section 20 of Commonwealth Act No. 103, which directs the CIR to act according to justice and equity and the substantial merits of the case, without regard to technicalities. This provision was deemed a sufficient standard to guide the court's discretion. The Court reiterated its previous ruling in Antamok Gold Fields Mining Company vs. Court of Industrial Relations et al., G. R. No. 46892, that such discretionary power is judicial in character and does not infringe upon the separation of powers, the prohibition against delegation of legislative function, or the equal protection clause. The Court also referenced the evolving tendency towards subordinate legislation and the approval of delegation of powers by the legislature, citing various cases where such delegation was upheld.
Main Doctrine
The Court of Industrial Relations has the authority under Section 4 of Commonwealth Act No. 103 to determine minimum wages in connection with an industrial dispute, and such grant of power is constitutional.