GR L 39117; (September 1975) (Digest)
G.R. No. L-39117 September 25, 1975
E. LIM & SONS MANUFACTURERS, INC., and ANTONIA SUN LIM, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, E. LIM and SONS MANUFACTURERS, INC. WORKERS UNION, et al., respondents.
FACTS
Petitioners, E. Lim & Sons Manufacturers, Inc. and its manager, were found guilty of unfair labor practice by the Court of Industrial Relations (CIR). The evidence established that upon the organization of the respondent union, the company engaged in harassment tactics. The union president, a senior technician, was demoted to janitorial duties. Management then declared it would not recognize the union or bargain collectively. Subsequently, the company terminated the employment of the union members, citing temporary closure due to excess inventory and lack of financing. However, business operations soon resumed with the hiring of new employees.
The petitioners appealed the CIR’s decision, challenging its validity on constitutional grounds. They contended that the designation of three acting judges to fill vacancies in the CIR, pursuant to a Presidential Letter of Instruction, was invalid. They argued that under the 1973 Constitution, only the Supreme Court could make temporary assignments of judges, and that the President’s action constituted an unlawful delegation of authority, encroaching on the Supreme Court’s supervisory powers over courts.
ISSUE
Whether the designation of acting judges to the Court of Industrial Relations by the President, after the effectivity of the 1973 Constitution, rendered the tribunal’s decision constitutionally infirm.
RULING
The Supreme Court dismissed the petition and affirmed the CIR decision. The constitutional challenge was devoid of merit. The Court reiterated the settled doctrine, established in Ang Tibay v. Court of Industrial Relations, that the CIR was not an integral part of the judicial system but was “more an administrative board.” Its functions were active, affirmative, and dynamic, unlike the passive role of a regular court. Therefore, the constitutional provisions regarding the Supreme Court’s power to assign judges of inferior courts temporarily were inapplicable to the CIR. The President’s authority to designate acting members to this administrative tribunal was not an encroachment on judicial power.
Consequently, the CIR that decided the case was a duly constituted tribunal. On the merits, the Court found the CIR’s factual findings—that the petitioners committed unfair labor practice through interference, restraint, and coercion of employees’ right to self-organization—to be supported by substantial evidence. The demotion, refusal to bargain, and discriminatory termination of union members constituted clear violations of the labor law. The attempt to nullify the decision on a procedural technicality, given the patent unfair labor practices, could not succeed. The decision of the CIR was affirmed.