GR L 17024; (July, 1962) (Digest)
G.R. No. L-17024. July 24, 1962.
GAPAN FARMER’S COOPERATIVE MARKETING ASSOCIATION, INC., petitioner-appellee, vs. FE PARIAL, LUCY CABATUANDO, REGIONAL OFFICE No. 3 DEPARTMENT OF LABOR, MANILA AND THE PROVINCIAL SHERIFF, CABANATUAN CITY, respondents-appellants.
FACTS
Respondents Fe Parial and Lucy Cabatuando, former employees of the Gapan Farmers’ Cooperative Marketing Association, Inc., filed complaints in December 1957 with Regional Office No. 3 of the Department of Labor for alleged unpaid wages under the Minimum Wage Law for periods spanning from 1954 to 1957. The Association contested the jurisdiction of the Regional Office and pleaded prescription. Despite these objections, a Hearing Officer rendered decisions in September 1958 ordering the Association to pay substantial sums to the employees. The Association’s appeals to the Labor Standards Commission were dismissed for being filed out of time. Subsequently, the Regional Administrator issued a writ of execution, prompting the Provincial Sheriff to enforce it.
Faced with the impending enforcement, the Association filed an action for certiorari with the Court of First Instance of Nueva Ecija. It sought to annul the Hearing Officer’s decisions and the writ of execution, arguing they were based on Section 25 of Reorganization Plan No. 20-A, which it claimed was unconstitutional. The trial court ruled in favor of the Association, annulling the decisions and enjoining their enforcement, leading to the present appeal by the respondents.
ISSUE
The core issue is whether Section 25 of Reorganization Plan No. 20-A, which empowered Regional Offices of the Department of Labor to hear and decide money claims and to issue writs of execution, is constitutional.
RULING
The Supreme Court affirmed the decision of the trial court, declaring the relevant provisions of Reorganization Plan No. 20-A unconstitutional. The legal logic rests on the principle of separation of powers and the statutory limits of Republic Act No. 997 , the law authorizing the reorganization plan.
Republic Act No. 997 authorized the reorganization of the executive branch only. By vesting Regional Offices with the authority to adjudicate money claims and issue executory writs, Reorganization Plan No. 20-A conferred judicial powers upon an administrative body within the executive department. The power to hear, decide, and enforce money claims is inherently judicial, belonging exclusively to the judiciary. This grant of judicial power to an executive agency exceeded the authority delegated by Congress under Republic Act No. 997 . Furthermore, it violated the constitutional doctrine of separation of powers by usurping functions constitutionally reserved for courts of justice. The Supreme Court found this view consistent with its established doctrine as laid down in Corominas vs. Labor Standards Commission and reiterated in a line of subsequent cases. Consequently, the “decisions” and writ issued by the Regional Office were null and void for lack of jurisdiction.
