### Facts:
Luzon Stevedoring Corporation (plaintiff-appellant) challenged the enforcement of the Anti-Dummy Law (Commonwealth Act No. 108, as amended by Republic Act No. 134) as interpreted by the Anti-Dummy Board (defendant-appellee), which prohibited the employment of non-American aliens in public utility corporations. This legal challenge originated from the appellant’s employment of nine non-American aliens, predating the Supreme Court decision in G.R. No. L-14859 (“Macario King, et. al. vs. Pedro S. Hernaez, etc., et. al.”). Following a letter from the defendant-appellee, based on the Secretary of Justice’s opinion, the plaintiff sought judicial construction regarding the employment of non-American aliens in public utility corporations in relation to Section 16(a) of the Public Service Act and Section 2-A of the Anti-Dummy Law.
Subsequently, the defendant-appellee filed an answer, posing three special defenses against the complaint, which indicated the plaintiff’s alleged violation of the laws concerning the employment of non-American aliens in its operation. Parties agreed on a judgment based on a stipulation of facts, which underscored the corporation’s nature as a public utility and detailed the employment of non-American aliens across various positions.
The legal proceedings focused not only on the procedural appropriateness of a declaratory relief petition but also on the fundamental interpretation of the Anti-Dummy Law’s restrictions regarding the employment of non-American aliens in public utilities, which the plaintiff argued should not apply to partly nationalized businesses like theirs.
### Issues:
1. Whether the petition for declaratory relief is the proper remedy given the plaintiff-appellant’s admitted breach of the law by employing non-American aliens.
2. The interpretation and applicability of Section 2-A of the Anti-Dummy Law in conjunction with Section 16(a) of the Public Service Act, particularly whether the prohibition against employing non-American aliens in public utility corporations applies solely to businesses completely nationalized.
### Court’s Decision:
The Supreme Court affirmed the decision of the lower court, holding that:
1. The petition for declaratory relief is not the proper remedy due to the plaintiff-appellant’s acknowledged violation of the law regarding the employment of non-American aliens before seeking judicial interpretation. However, due to the significance of the issue at hand, the Court proceeded to address the substantive legal questions for guidance.
2. The Court rejected the plaintiff’s argument that the Anti-Dummy Law’s restrictions only applied to wholly nationalized businesses. It clarified that the law and its amendments intended to prevent any workaround that would subvert nationalization laws, regardless of whether such laws provide for complete or partial nationalization. It stated that corporations or associations at least 60% owned by Filipino citizens fall under the ambit of businesses that cannot employ non-American aliens in positions related to the management, operation, administration, or control thereof.
### Doctrine:
The Supreme Court reiterated the doctrine that laws must be interpreted to give effect to their intended purpose, emphasizing that restrictions on the employment of non-American aliens in public utilities apply to both wholly and partially nationalized corporations to safeguard economic and national security interests.
### Class Notes:
– **Declaratory Relief:** Not the appropriate remedy if the party seeking it has already breached the law.
– **Anti-Dummy Law (Commonwealth Act No. 108, as amended):** Prohibits the employment of non-American aliens in roles that involve management or control in businesses or rights reserved by law to Filipino citizens or entities at least 60% owned by them.
– **Public Service Act (Commonwealth Act No. 146, Section 16(a)):** Public utilities need to be at least 60% owned by Filipino citizens or corporations for operations in the Philippines.
– **Interpretation of Laws:** Emphasizes that laws aimed at nationalization or reservation of certain rights, privileges, or businesses to Filipino citizens or entities should be interpreted broadly to prevent circumvention and ensure the law’s objectives are achieved.
### Historical Background:
This case highlights the legal tensions and interpretations surrounding the employment of foreigners in the Philippines’ public utility sectors. It reflects the country’s effort to balance national interests, economic development, and compliance with constitutional and statutory requirements during a period of increasing globalization and foreign involvement in local industries.
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