Professional Documents
Culture Documents
FACTS
ISSUES + RULING
Does CA 103 violate the principle of separation of powers and the
doctrine on delegation of powers? NO.
CA 103 gives the CIR full discretion to resolve and decide agrarian
and industrial disputes in the manner it believes to be fair and
equitable, regardless of technicalities or legal forms (Article 20),
and the power thus granted is judicial rather than legislative.
o So it does not violate the principle of separation of powers,
the prohibition on delegation of legislative powers or equal
protection before the law.
o CA 103, which provides for the protection of the worker by
creating a CIR empowered to:
Fix a minimum wage for the workers and the maximum
rent to be paid by the tenants
Enforce compulsory arbitration between employers or
owners and employees or tenants, respectively,
o And prescribes penalties for breach of its decrees, has been
promulgated by the National Assembly pursuant to the
precepts contained in the 1935 Constitution
In compliance with these precepts, the National
Assembly promulgated CA103 creating the CIR which is
a special court with judicial powers
Are the legal powers CA 103 grants to the CIR so arbitrary and
unreasonable that they allow deprivation of liberty and property without
due process of law violates the Constitution which prescribes that the
Supreme Court shall issue rules and procedure for all courts of the same
category? NO.
Article 20 (Note: This provision is similar to Article 227 [221] of the
Labor Code re: Labor Arbiters and the National Labor Relations
Commission) has not empowered the CIR to investigate and resolve
questions and disputes between workers and employers and
tenants and owners in an arbitrary and capricious manner without
being subject to a specific rule of conduct.
o Article 20 clearly stipulates that the rules of procedure
which it adopts, to which the court must conform, must be
based on justice and equity, and prescribes that the criterion
which must be formed must be based on the substantial
merits of the case, without regard to technicalities or legal
forms.
o CA 103 cannot be challenged on the ground that authorizes
the deprivation of liberty and property without due process of
law nor does it conflict with the precept of Section 13, Article
VIII, of the Constitution because the CIR is not of the same
category as the municipal courts, courts of justice and
courts of first instance for which the regulations of the
Courts by the Supreme Court [apply].
Re hearing: the parties were duly represented, were heard and
presented the evidence that they had available and thought it
convenient to offer. Such inspection and hearings had the
character of an impartial and fair judicial hearing and constitute
the due process of law guaranteed by the Constitution.