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3 Automotive Industry Workers Alliance v. Romulo, 449 SCRA 1

The petitioners, several labor unions, sought to declare an executive order unconstitutional that transferred administrative supervision over the National Labor Relations Commission from its chairperson to the Secretary of Labor and Employment. The petitioners argued this amended existing law in violation of separation of powers. However, the court ruled the petitioners lacked standing to challenge the order as they did not demonstrate how their rights would be harmed by the order, which was limited in scope and did not require additional appropriations. Additionally, the president has authority under the doctrine of qualified political agency to oversee the NLRC through department secretaries. Therefore, the court dismissed the petition.

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108 views1 page

3 Automotive Industry Workers Alliance v. Romulo, 449 SCRA 1

The petitioners, several labor unions, sought to declare an executive order unconstitutional that transferred administrative supervision over the National Labor Relations Commission from its chairperson to the Secretary of Labor and Employment. The petitioners argued this amended existing law in violation of separation of powers. However, the court ruled the petitioners lacked standing to challenge the order as they did not demonstrate how their rights would be harmed by the order, which was limited in scope and did not require additional appropriations. Additionally, the president has authority under the doctrine of qualified political agency to oversee the NLRC through department secretaries. Therefore, the court dismissed the petition.

Uploaded by

JB Guevarra
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Aristoza

CONSTITUTIONAL LAW 1 1.1. NLRC personnel who will be subjected to Sec’s authority have
direct and specific interest
Automotive Industry Workers Alliance (AIWA) v Romulo 1.2. Congress can claim injury in the encroachment of their
January 18, 2005 legislative function.
THE CASE: 2. No. EO 185 is limited to the departments it addresses; only relations
created is between the official issuing it and those receiving it
PONENTE: Chico-Nazario, J.
PETITIONERS: Olsen v Herstein and Rafferty
RESPONDENTS: “…executive order can be considered nothing more or less than a
command from a superior to an inferior”
PROVISIONS APPLICABLE:
doctrine of qualified political agency- department secretaries are alter In this matter, it is administrative in nature: an attempt to make more
egos or assistants of the President and their acts are presumed to be those efficient and economical operations of the departments.
 hence, no right of 3rd parties are created nor affected.
of the latter unless disapproved or reprobated by him
Because of its limited reach, Court has ruled that is not one of those
exceptional occasions where Court can exercise judicial review.
FACTS:
 Petitioners (10 labor unions) call to declare an EO unconstitutional as it Reynato Puno, dissent, Kilosbayan case:
violates separation of powers Ratio for locus standi: to ensure that a vigorous adversary
 EO 185: transferred administrative supervision over National Labor presentation of the case is at hand; go to the essence of
Relations Commission (NLRC), regional branches, and personnel from representative democracies- to warrant the judiciary’s overruling the
NLRC Chairperson to Sec. of Labor and Employment determination of a coordinate, democratically elected organ of
 Petitioners assert that EO 185 amended the law (reverting NLRC state to government; economic reasons- to open doors to all types of suits
pre-RA 6715 set-up), a power only the Congress has will result in ineffective dispensers of justice
 Respondents
1.1. there is no actual controversy as petitioners have not stated how RULING
EO 185 can prejudice/harm their rights WHEREFORE, premises considered, the instant petition dated 27 March
1.2. petitioners have no standing: (a) they are not taxpayers as labor 2003 is hereby DISMISSED for lack of merit. No costs.
unions are exempt from paying taxes (Tax Reform Act of 1997) SO ORDERED.
and (b) even if they were taxpayers, EO 185 would require no
additional appropriation for implementation
1.3. president, under Art. 7 Sec. 17, has the power to oversee NLRC
operations through their alter ego Sec. of Labor, pursuant to the
doctrine of qualified political agency

ISSUES
1. WoN petitioners have locus standi
2. WoN there is an issue of transcendental importance so as locus
standi can be set aside

HELD/RATIONALE
1. No. Petitioners have not shown that they will sustain injury should
EO 185 be enacted. Their rights are not affected as Sec. of Labor
has no power to revise or modify NLRC decisions. As taxpayers, no
additional appropriation will spring from enactment of EO.

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