**Facts:**
1. September 25, 1963: The Registrar of Labor Organizations issued a notice to the Social Security System Employees Association (SSSEA) to appear for a hearing on October 17, 1963. The notice alleged that the SSSEA failed to file financial reports and did not submit proper documentation of its officers, in violation of Section 23 of Republic Act No. 875.
2. October 17, 1963: SSSEA’s counsel moved to postpone the hearing to October 21, 1963, with intentions to present a memorandum and the requested documents. The motion was granted.
3. October 21, 1963: No representative from SSSEA appeared for the hearing.
4. October 22, 1963: Manuel Villagracia, an assistant secretary of SSSEA, submitted a letter enclosing certain documents including the joint non-subversive affidavit of the officers and a list of newly elected officers. The Registrar decided that these documents did not fulfill the requirements outlined in the notice.
5. October 23, 1963: The Registrar canceled SSSEA’s registration certificate, citing non-compliance with filing requirements.
6. October 28, 1963: Alfredo Fajardo, president of SSSEA, moved for reconsideration of the cancellation and requested more time to submit the requisite documents.
7. Opposition arose from Paulino Escueta, a member of SSSEA, for failing to submit financial statements to its members. A hearing was conducted on November 27, 1963.
8. December 4, 1963: The Registrar issued an order stating that SSSEA failed to comply with earlier requirements, yet allowed another 15 days for compliance.
9. December 16, 1963: The petitioners (PAFLU, SSSEA, and certain SSSEA officers) filed the present case requesting certiorari and prohibition against the enforcement of Sections 23 of Republic Act 875, claiming the sections infringed their rights, among other complaints.
**Issues:**
1. **Constitutionality of Section 23 of Republic Act No. 875**: Does it violate the freedom of assembly and association?
2. **Judicial vs. Administrative Function**: Is the determination of compliance a judicial power improperly delegated to an administrative authority?
3. **Compliance with ILO Convention No. 87 and the Universal Declaration of Human Rights**: Does Section 23 conflict with these international commitments?
4. **Procedural Validity**: Were procedural timelines adhered to, and was there an exhaustion of administrative remedies?
**Court’s Decision:**
1. **Constitutionality**: The Court held that Section 23 of RA No. 875 does not infringe on constitutional rights. Registration requirements are conditions to acquire legal personality and statutory rights, not constitutional rights, thus a lawful exercise of police power.
2. **Judicial vs. Administrative Function**: The Court clarified that determining compliance with registration requirements does not constitute judicial power. Administrative agencies can decide such matters as part of their quasi-judicial function, provided due process is afforded.
3. **International Conformity**: The Court found no inconsistency with international instruments like ILO Convention No. 87 or the Universal Declaration of Human Rights. SSSEA’s rights under these documents remain unimpeded.
4. **Procedural Validity and Exhaustion of Remedies**: The petition was deemed premature as the Secretary of Labor had not resolved the motion for reconsideration filed by the SSSEA. Petitioners had not exhausted all administrative remedies.
**Doctrine:**
The doctrine emphasizes the regulatory role of labor registration as an essential component of lawful control over labor rights without infringing constitutional freedoms. The legislation’s requirement for registration and compliance is a valid exercise of government oversight to protect public interest and ensure union integrity.
**Class Notes:**
– **Legal Personality**: Acquired through compliance with registration laws.
– **Police Power**: Justifies regulation in public interest.
– **Due Process in Administrative Proceedings**: Requires opportunity for hearing before agency action.
– **Exhaustion of Administrative Remedies**: A prerequisite to judicial intervention.
**Historical Background:**
The case occurred in a post-war Philippines during an era of labor activism and unionization, reflecting the government’s balancing act between affirming workers’ rights and enforcing regulatory frameworks to prevent abuse and promote transparency within labor movements. Amidst global movements for labor rights, this case also underscores the Philippine legal system’s interplay with international labor standards.
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