GR 58184; (October, 1981) (Digest)
G.R. No. L-58184 October 30, 1981
FREE TELEPHONE WORKERS UNION, petitioner, vs. THE HONORABLE MINISTER OF LABOR AND EMPLOYMENT, THE NATIONAL LABOR RELATIONS COMMISSION, and THE PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, respondents.
FACTS
The Free Telephone Workers Union (FTWU) filed a notice of strike against the Philippine Long Distance Telephone Company (PLDT) on September 14, 1981, citing unfair labor practices, including the unilateral implementation of a harsh Code of Conduct, illegal terminations, and violations of their Collective Bargaining Agreement. After conciliation meetings failed, the union complied with legal strike requirements. On September 25, 1981, the Minister of Labor, invoking the amended Article 264 of the Labor Code (Batas Pambansa Blg. 130), certified the labor dispute to the National Labor Relations Commission (NLRC) for compulsory arbitration and enjoined any strike at PLDT, a public utility deemed vital to national interest.
ISSUE
The primary issue is whether Batas Pambansa Blg. 130, which amended Article 264 of the Labor Code by granting the Minister of Labor the power to assume jurisdiction or certify labor disputes in industries affecting national interest for compulsory arbitration, constitutes an undue delegation of legislative power. A secondary issue is whether such power violates the constitutional rights of workers to self-organization and collective bargaining.
RULING
The Supreme Court dismissed the petition. On the crucial issue of undue delegation, the Court held that the amendatory law did not constitute an invalid delegation of legislative power. The grant of authority to the Minister of Labor is not an unbridled delegation but is circumscribed by a sufficient standard: the existence of a labor dispute “adversely affecting the national interest.” This standard provides an intelligible principle to guide the executive branch in its exercise of discretion, as the law specifically enumerates examples of such vital industries, including public utilities like PLDT. The Court cited established jurisprudence that such delegations are permissible when accompanied by adequate standards.
Regarding the constitutional challenge, the Court ruled that the petition was premature. While compulsory arbitration in industries affecting national interest is constitutionally permissible, its application must not infringe on the fundamental state policy to afford protection to labor and assure the rights to self-organization and collective bargaining. The Court found that at this stage, there was no factual determination by the labor authorities upon which to base a ruling on whether there was an unconstitutional application of the law in this specific instance. The union’s allegations were merely speculative. Thus, the petition could not prosper, and the matter was properly left for the Ministry of Labor and the NLRC to resolve in the compulsory arbitration proceedings.