G.R. No. L-16017, August 31, 1961
Philippine Tobacco Flue-Curing & Redrying Corporation, plaintiff-appellee, vs. Manuel Sabugo, Fructuoso Alban as Chief, Labor Relations Section, and Pedro A. De Leon, as Hearing Officer Regional Office No. 1, Dept. of Labor, defendants-appellants.

FACTS

Manuel Sabugo filed a complaint for overtime pay against the Philippine Tobacco Flue-Curing & Redrying Corporation before Regional Office No. 1 of the Department of Labor, invoking the jurisdiction granted to such regional offices under Reorganization Plan 20-A. The corporation, contending that Plan 20-A was unconstitutional, filed a petition for prohibition with the Court of First Instance of Quezon City to restrain the labor officials from hearing Sabugo’s claim. The lower court granted the petition and issued the writ of prohibition.
The trial court ruled in favor of the corporation on two primary grounds. First, it held that Plan 20-A effected an undue delegation of judicial power to an administrative body by conferring upon the regional offices original and exclusive jurisdiction over money claims. Second, it declared Plan 20-A a nullity for failing to comply with constitutional procedures for the enactment of laws.

ISSUE

The core issue is whether Reorganization Plan 20-A validly conferred upon the regional offices of the Department of Labor the jurisdiction to hear and adjudicate money claims, such as the overtime pay claim filed by Sabugo.

RULING

The Supreme Court affirmed the lower court’s decision, declaring Reorganization Plan 20-A invalid. The legal logic rests on two independent constitutional infirmities. First, the Court held that the plan constituted an invalid delegation of judicial power. The Government Survey and Reorganization Commission, created to reorganize the Executive Branch, was empowered by Republic Acts Nos. 997 and 1241 to create administrative functions, not judicial ones. Judicial power is vested exclusively in the judiciary by the Constitution. While the legislature may grant administrative bodies quasi-judicial powers incidental to their administrative functions, it must do so expressly. Plan 20-A’s grant of exclusive and original jurisdiction over money claims went beyond such incidental authority and improperly vested a judicial function in an executive agency.
Second, the Court rejected the argument that the plan became law through legislative inaction under Section 6(a) of Republic Act No. 997 , which provided that plans would be deemed approved if not disapproved by Congress within a set period. This “deemed approved” mechanism was held unconstitutional. It violated the prescribed legislative process, which requires affirmative action by both houses of Congress through separate deliberations and votes, followed by presentment to the President for approval or veto. A procedure whereby a law is created by congressional silence or adjournment is alien to the Philippine constitutional system. Consequently, Plan 20-A never validly took effect as law. Since the plan was invalid, the regional office lacked jurisdiction over Sabugo’s claim, and its purported power to issue writs of execution similarly failed.