G.R. No. L-18734. December 30, 1961.
GOVERNMENT SERVICE INSURANCE SYSTEM EMPLOYEES’ ASSOCIATION (GSISEA), ET AL., petitioners, vs. COURT OF INDUSTRIAL RELATIONS and GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), respondents.

FACTS

Petitioner unions sought to prohibit the Court of Industrial Relations (CIR) from hearing a labor dispute between them and the GSIS management concerning the implementation of salary standardization provisions in their collective bargaining agreement. The dispute had been certified to the CIR by a letter dated August 15, 1961, signed by then Executive Secretary Natalio P. Castillo “by authority of the President.” The letter stated that, considering the GSIS’s indispensable role and the potential consequences of a strike, the President was certifying the dispute to the CIR pursuant to Section 10 of Republic Act No. 875 (the Industrial Peace Act).
The unions challenged the validity of this certification. They argued, first, that the President was in the Visayas on the letter’s date and there was no proof he authorized the Executive Secretary to act. Second, they contended that the President’s certification power under Section 10 of R.A. 875 is non-delegable to a cabinet member.

ISSUE

Whether the certification of the labor dispute to the Court of Industrial Relations, effected through a letter signed by the Executive Secretary “by authority of the President,” was valid.

RULING

The Supreme Court upheld the certification’s validity and dismissed the petition. The legal logic centered on the presumption of regularity in official acts and the absence of a statutory form for presidential certifications. The Court clarified that the Executive Secretary’s letter was not an exercise of delegated power but an attestation that the President himself had ordered the certification. The statute does not prescribe a specific form, so a certification need not be personally signed by the President. The President’s physical absence from Manila did not preclude him from issuing the order, given modern communication facilities.
The presumption that official duty was regularly performed applied to the Executive Secretary’s act. To assume he falsely attested to the President’s order would be to infer a criminal act (falsification) without evidence. Furthermore, respondents demonstrated that the President had personally approved the GSIS Manager’s prior request for certification. Thus, no improper delegation occurred. The timing of the certification before an actual strike was irrelevant, as Section 10 requires only an existing industrial dispute, which was conceded. The certification was therefore proper, and the CIR correctly assumed jurisdiction.