G.R. No. L-20315; June 30, 1964
CHUNG QUIAO alias BINA TAN, petitioner-appellee, vs. ANITA ABADAY, ET AL., respondents-appellants.

FACTS

Anita Abaday and Juanita Isoy filed claims for underpayment of wages, overtime, and separation pay against their employer, Chung Quiao alias Bina Tan, before the regional office of the Department of Labor in Cagayan de Oro City. The hearing officer, after declaring the employer in default for failure to appear, rendered separate decisions ordering the employer to pay the claimants specific sums. These decisions became final and executory, prompting the hearing officer to issue a writ of execution to the provincial sheriff.
To prevent enforcement, Chung Quiao filed a petition for injunction with the Court of First Instance of Misamis Oriental, which granted a preliminary injunction. After the parties submitted a stipulation of facts, the trial court rendered a decision declaring the hearing officer’s decisions unenforceable and making the injunction permanent. The court held that under Republic Act No. 602 , the hearing officer lacked the judicial authority to render binding and enforceable decisions on money claims, a power reserved solely to courts of justice. The claimants, respondents herein, appealed this decision.

ISSUE

Whether the hearing officer of the regional labor office had valid judicial authority to adjudicate and enforce the money claims against the employer.

RULING

The Supreme Court affirmed the trial court’s decision, ruling that the hearing officer’s decisions were legally ineffective and unenforceable. The respondents argued that Reorganization Plan No. 20-A, adopted under Republic Acts Nos. 997 and 1241, granted regional offices original and exclusive jurisdiction over such money claims and the power to enforce their final decisions like courts. Specifically, they cited Sections 20 and 25 of the Plan, which purported to confer this judicial authority.
The Court rejected this contention, adhering to its settled jurisprudence. It held that Reorganization Plan No. 20-A, insofar as it conferred judicial powers upon labor officials to adjudicate claims beyond the scope of the Workmen’s Compensation Commission, was unconstitutional. This constituted an undue delegation of legislative power, not authorized by Republic Act 997, as amended. The Court clarified that Congress’s failure to disapprove the Plan did not cure this defect or transform it into a valid statute, as proper constitutional procedures for lawmaking were not followed. Citing precedents such as Miller v. Mardo, the Court reiterated that the Plan was invalid and of no effect regarding the grant of such judicial powers. Consequently, the hearing officer acted without jurisdiction, and his decisions could not be enforced via a writ of execution.