GR L 17016; (April, 1962) (Digest)
G.R. No. L-17016; April 25, 1962
WORLDWIDE PAPER MILLS, INC., petitioner-appellant, vs. LABOR STANDARDS COMMISSION and ERNESTO PALOMIQUE, respondents-appellees.
FACTS
On June 20, 1958, respondent Ernesto Palomique filed a complaint with Regional Office No. 3 of the Department of Labor against petitioner Worldwide Paper Mills, Inc., seeking recovery of unpaid overtime wages and separation pay. In its answer, the petitioner interposed the special defense of lack of jurisdiction, contending that Reorganization Plan No. 20-A and its implementing rules, which granted the regional office authority to adjudicate such money claims, were unconstitutional. The regional hearing officer rendered judgment in favor of Palomique, ordering the petitioner to pay the claimed amounts.
The petitioner appealed to the Labor Standards Commission, reiterating its jurisdictional challenge. The Commission sustained the regional office’s jurisdiction, ruling that the Reorganization Act ( Republic Act No. 997 , as amended) provided sufficient authority. Subsequently, the petitioner filed a Petition for Certiorari and Prohibition with the Court of First Instance of Manila, which likewise upheld the validity of Reorganization Plan No. 20-A. The case was elevated to the Supreme Court on the singular issue of the Plan’s validity.
ISSUE
Whether Reorganization Plan No. 20-A, particularly Section 25, which granted regional offices original and exclusive jurisdiction over money claims of laborers, is valid.
RULING
The Supreme Court ruled that Reorganization Plan No. 20-A, specifically Section 25, is null and void. The legal logic is anchored on the principle of non-delegation of legislative power and the separation of powers. Republic Act No. 997 , which created the Reorganization Commission, did not authorize the transfer of judicial powers from the courts to executive officials or offices created by the Plan. The legislature cannot delegate its core power to create courts of justice or to confer judicial jurisdiction to an executive body like the Reorganization Commission.
The Court, citing a line of precedents including Cagalawan v. Customs Canteen and Corominas, Jr. v. Labor Standards Commission, held that the grant of original and exclusive jurisdiction over money claims to the regional offices was made without statutory authority and was therefore unconstitutional. Consequently, the regional office and the Labor Standards Commission lacked jurisdiction to hear and decide Palomique’s claim. The appealed decision was set aside, and the case was dismissed, reserving to Palomique the right to institute the appropriate action before the proper court of justice. No costs were awarded.