MANILA CORDAGE COMPANY, PETITIONER, VS. THE COURT OF INDUSTRIAL RELATIONS AND MANILA CORDAGE WORKERS UNION-­PAFLU, RESPONDENTS.

Petition for review on appeal from the order of the Court of Industrial
Relations of November 11, 1965 denying petitioner’s motion to either dismiss or
suspend the proceedings in Case No. 62-IPA of said court which were started by virtue of a
Presidential certi­fication dated October 22, 1965 of “a labor dispute between
the management of the Manila Cordage Company (herein petitioner) and the members of the Manila Cordage Workers
Union – PAFLU (herein private respondent). . .,” as well as its subsequent order dated November 26, 1965
but released much later and received by petitioner only on April 19, 1966
denying petitioner’s motion for
reconsideration of the denial order.

The grounds of the
petition are substantially stated in petitioner’s assignment of errors thus:

“I

“THE RESPONDENT COURT
ERRED IN NOT INHIBITING ITSELF FROM EXERCISING JURIS­DICTION OVER THE CASE, THE
PRESIDENTIAL CERTIFICATION, UNDER WHICH IT ASSUMED JURISDICTION, HAVING BEEN
MADE WITHOUT BASIS IN FACT.

“II

“ASSUMING ARGUENDO THAT THE RESPON­DENT
COURT COULD HAVE ASSUMED JURISDIC­TION UNDER THE
PRESIDENTIAL CERTIFICA­TION, IT ERRED IN NOT REFRAINING FROM EXERCISING ITS COMPULSORY ARBITRATION POWERS, A RETURN-TO-WORK AGREEMENT AND A
COLLECTIVE BARGAINING AGREEMENT HAVING BEEN REACHED BY PETITIONER AND
RESPON­DENT UNION.

“III

“THE RESPONDENT COURT
ERRED IN NOT DISMISSING OR AT LEAST SUSPENDING THE PROCEEDINGS IN VIEW OF THE
PENDENCY OF CASES BETWEEN THE SAME PARTIES INVOLV­ING THE SAME ISSUES COVERED
BY THE PRES­IDENTIAL CERTIFICATION.”

Unfortunately, the background facts upon which the legal issues
in which parties joined in the lower court may be resolved are not stated in
the impugned orders, and it is precisely because of the failure of the
respondent court to make a finding on the principal factual is­sue raised by
private respondent that this case is hereby being ordered returned to
respondent court for further proceedings. 
Such failure, however, does not preclude this Court from passing now on
some of the questions raised in the pleadings on the basis of the other facts
in the record which are undisputed although they appear to have been merely
assumed in the orders under review, if only to guide the course of such further
proceedings.

On or about May 16, 1965,
respondent union which is composed of workers in petitioner
company declared a strike against said company.  On October
14, 1965, an agreement was signed by C. A. Carter, the President of
the Company, on its behalf, and by certain persons, headed by Juanito Tabuyan, purportedly as
president, vice-pres­ident, secretary, treasurer, auditor and directors of
respondent Union, on behalf of the said union, providing
as follows:

“1.  The UNION shall, upon
the signing of this Agreement, call
off and withdraw the picketing at or about the COMPANY’s
premises and officially terminate the strike declared on May 16, 1965 and the said picketing.

“2.  The
COMPANY agrees to accept on a staggered basis, depending upon the requirements
of the COMPANY’s business and operations, all
employees who have not yet returned to work as of the date of this Agreement,
with the exception of em­ployees facing
or involved in criminal cases and other cases pending in any court, office,
agency or instrumentality of the government whose readmission for work will
depend upon the resolution of said cases.

“The employees not falling within the exception above
mentioned shall report to the COMPANY not later than October 31, 1965 for advice as to when they can
act­ually start working.  Should these
employees fail to report on or before Oct­ober
31, 1965, they shall be considered to have abandoned their jobs
with the COM­PANY and the COMPANY shall then be free to hire their
replacements.

“3.  The COMPANY hereby reserves its right, which
the UNION hereby expressly recognizes, to prosecute all the cases it (the
COMPANY) has filed and are pend­ing, and to file and prosecute any other cases,
in any court, office, agency and/or instrumentality of the government, in
connection with the said strike and picketing and to take such action as the COMPANY sees fit upon the resolution
of these cases.  It is hereby understood and agreed
that this Agreement shall not be construed,
in any manner and for any reason, as a condonation by
the COMPANY of any and all acts
committed by the em­ployees during the said strike and picketing subject of the
cases already filed and to be filed against said employees.

“4.  The UNION assures and
guarantees the reestablishment and maintenance of industrial peace in the
COMPANY.

“5.  Any grievance of the UNION
and the employees, represented by the UNION, shall be
processed in accordance with the prov­isions of the Collective Bargaining Agree­ment
existing between the UNION and the COMPANY.

“6.  The UNION guarantees
that this Agreement has been duly ratified by its membership.”

There seems to be no controversy as to
the fact that this above return-to-work provision was immediately duly
implemented by the Company as well as the members of the Union,
other than those herein purportedly acting for the Union,
“200” in number, represented by Atty. Israel Bocobo.

It was at this juncture that the aforementioned presidential
certification was issued, and pursuant thereto the respondent court assumed
jurisdiction over this case.

As a first step to take the case out of the indus­trial court,
petitioner requested the President in a letter dated October 30, 1965 to withdraw or recall the
certification.  This request was endorsed
by the Executive Secretary to the Secretary of Labor and the latter, in a 2nd indorsement dated November
12, 1965, recommended to the President favorable action on petitioner’s
request, but no action appears to have been taken by the President on this
recommendation.

In the meanwhile, on December
23, 1965, a new collective bargaining agreement was signed between
the same persons who signed the above-mentioned return-to­-work agreement of
October 14th, except that, on behalf of
the Union, a certain Adolfo Espano
signed additionally as Executive Vice-President and, on the other hand, none of
the directors were included, in this later agreement.

In two successive motions, the first on October 30, 1965 and the
second on November 5, 1965, petitioner sought again to take the case out of the
court by asking for either the
dismissal or suspension of the proceed­ings upon the grounds that:

(A)  
it was seeking recall of the
presiden­tial certification and

(B) 
1. This Honorable Court has no
jurisdic­tion over this case because –

(a)   
The presidential certification is
not valid and conclusive;

(b)   
In any case, there is doubt as to
the propriety of the presidential certification and/or the exercise by this
Court of compulsory arbitration powers for the reasons that –

(i)    There is no labor dispute between the
petitioner and the respondent;

(ii)   The business of respon­dent is one not
indispensable to the national interest;

(iii)   The so-called “dispute”, granting, arguendo, that there is any, is one involving a small faction in the
petitioner union, which “dispute” does not warrant presidential
certification and/or operation of compulsory arbitration.

2. Granting, without
admitting, that this Court has jurisdiction, this Court should not exercise its
compulsory arbitration powers for such exercise would –

(a)    
Modify, alter or weaken, if not
impair, the existing collective bargain­ing agreement between the petitioner
and the respondent;

(b)    
Violate the letter and the spirit
of the Industrial Peace Act and destroy the fabric of free and voluntary
collective bargaining.

In connection with said motions, on
November 15, 1965, the same persons who signed the collective bargaining agreement
of December 23, 1965, as aforestated, filed over
their signatures a manifestation to the effect that “there exists no labor
dispute between the petitioner and the respondent company, that the strike
declared last May 16, 1965 has been officially terminated last October 14,
1965, and that petitioner has instructed its members to stop picketing.”

In the foregoing circumstances, the orders of denial of the
respondent court would indeed seem to be less than justified.  It appears, however, albeit not in the said
orders nor in the answer but, in the
petition itself, (Par. 13, pp. 8-9) that a so-called “small group of
strikers — being represented by Atty. Israel Bocobo“,
evidently the one referred to in the questioned order of November 11, 1965 as
“200” others, (Exhibits “A” -“A-1”, Strikers), [p. IV
Appendix A, Petitioner’s Brief actually took part in the hearing of
petitioner’s two motions for dismissal or suspension and thereat alleged that:

“During the initial hearings, a certain group headed by Mr. Tabuyan (who had even at the early stages of the strike,
crossed the picket lines) through counsel, made representations to this
Honorable Court that even before the issuance of the pres­idential
certification, there had been a ‘return to work agreement’ between them and the
respondent management.  The impli­cation
therefore is that they were not on strike at the time of the presidential
certification.  Obviously therefore they
have nothing to do with the strikers and the strike certified by the President.

“This group during the hearings submit­ted to court the
purported ‘agreement’, a document showing
the list of their ‘mem­bers’ and a certification by the company that several of
these workers had returned to work.

“To this, the
petitioner union made the following manifestations and observations, among
others:

“1.  The Tabuyan group is
a spurious group headed by ‘strike-breakers’;

“2.  It does not recognize the agreement;

“3.  Since the hearing was for a possible return-to-work
order by the court, it was pre-mature to go into the merits as to the validity
of the claims of Tabuyan who after all admits they
are not strike at all.

“With these observations, petitioner union reserved the
contesting of the claims of Tabuyan.  Tabuyan however was
allowed to hand over the documents to the court, but without benefit of a hearing
on the merits. There could possibly be no judicial finding then as to the
existence of such a return-to-work agreement.

“It may also be considered that if there was such a
return-to-work agreement then there was no strike at all that could be
certified to the court by the President of the Philippines.  Indeed, the respondent management raised this
contention on several occasions.

“We hasten to
add also that respondent management aside from claiming falsely that there is
no more strike has used this spur­ious agreement to sow confusion and demorali­zation
among the strikers by announcing that those who would not follow the return to
work provided in the agreement are subject to dismissal.”

It was on the
backdrop of these circumstances that respondent court issued the first
challenged order which reads thus:

“This refers to respondent company’s motion to suspend
proceedings filed with the Court on November 3, 1965, and to its motion to
dismiss for lack of jurisdiction which it verbally interposed at the hear­ing
of the same date and formally filed on November 6, 1965, under the heading
‘Motion to Dismiss and to
Suspend Proceed­ings.’

“In assailing the jurisdiction of the Court, respondent
questions the wisdom and propriety of the presidential certifi­cation.  This is no concern of the Court but
exclusively devolves upon the President (Pampanga
Sugar Development Co. Inc. vs. CIR, et al., G.R. No. L-13178, March 25, 1961).  The existence of a labor dispute between the
parties is not disputed; hence, the Court should proceed to exercise
jurisdiction under Sec. 10, of R. A. 875. 
Con­fronted with the same issue, this Court, in ‘Central Ma-ao Workers Amalgamated – PAFLU vs. Ma-ao
Sugar Central Company, Inc.,’ Case No. 56-IPA, upheld jurisdiction.  There is no reason to deviate from that stand
and from the ruling of the Supreme Court.

“The number of employees involved in a certified case, whether
great or small, is immaterial.  Section
10 of Republic Act 875 merely requires that the labor dispute involve an
industry indispensable to the national interest.  The business of respon­dent company has been
found to be one such industry.

“It is also argued that under the theory of exhaustion of
administrative remedies, the Court should suspend proceedings pend­ing action
on respondent’s letter to the President for the recall of his certifica­tion.  While respondent may avail itself of
administrative remedies, the Court, whose function to arbitrate without delay
is clear, may meantime legally proceed to exercise jurisdiction provided the
rights of the parties are not thereby prejudiced and vital industrial peace as
well as pre-conflict operation of the business concerned, restored.  In the event the President recalls his
certification, the parties may revert to their positions prior thereto.

“Anyway, at
this stage, the Court is most concerned with the return to work of the
strikers.  Respondent has entered into a
return-to-work agreement with the Manila Cordage Workers Union – PAFLU, and has
admitted back to work the striking employees who were represented by the
signatories on behalf of the union.  Such
an agreement does not bar a presidential certification of the dispute inasmuch
as ‘the relations between capital and labor are not merely contractual.  They are so impressed with public interest
that labor contracts must yield to the common good.  x x
x’ (Art. 1700, Civil Code.).  In
virtue of said certifi­cation it will be discriminatory under the circumstances
for respondent not to readmit the other strikers not so represented.  There is therefore no harm if a return to
work of the striking members is effected.

“The Court is aware of the pendency
of Cases Nos. 175-INJ and 4325-ULP, involving the same parties and, among
others, the issue of illegality of strike arising from the means employed
during the picketing.  Some strikers were
criminally charged for acts allegedly committed during the strike.  And were it not for the return-to-work agree­ment
earlier adverted to, the issue of ille­gality of the strike would take
preference over the reinstatement of the workers still on strike.  Likewise the Court notes that were it not for the matter of the
reinstatement of the workers criminally charged, there would have been complete
accord between the parties as to the return to work of the other striking
workers.  For this reason, in order that
the issues raised in those two cases be not prejudiced
by the exercise of jurisdic­tion in the instant case, the strikers who have
been charged with criminal offenses in the conduct of the strike should not, in
the meanwhile, return to work.

“From manifestations before the Court, there are only 33 of
these employees so charged criminally, as against 200 others, (Exhibits ‘A’ –
‘A-1, Strikers) who will not stand to be benefited by a return to work.  The records also show that respondent manage­ment,
if there would be a return to work at all, would be willing to reduce their
number.  Respondent manifested however,
that because of the difficulty of determining the degree of culpability of
each, it may not be in a position to reduce their number meantime.

“WHEREFORE, upholding jurisdiction, the motion to dismiss
and/or suspend proceedings, is hereby DENIED. 
Consequently, the strikers represented by Atty. Israel Bocobo are hereby directed to lift their picket lines and
re­turn to work forthwith, excepting the 33 strikers who have been charged
criminally and who should not return to work as yet.  Respondent
is hereby directed to accept back to work the strikers whose names appear in the payroll of the company
immediately preced­ing the strike, excepting those criminally charged.

“The above-entitled case is hereby set for hearing on November 17, 1965, at 2:00 P.M., to find out whether management would
be able to reduce the number of those who would not return to work meantime.

“SO ORDERED.”

On these premises, the main target of petitioner’s attack is the
respondent court’s refusal to declare it­self without jurisdiction to give due
course to the presidential certification above-mentioned.  Petitioner’s theory in support of this
posture is that the said cer­tification “appears to have been made on
(the) erroneous factual bases” of the existence of “a labor dispute
bet­ween the COMPANY and the UNION”, “that the business of the
COMPANY is not indispensable to the national in­terest” and if, at all,
“the ‘dispute’ involves only a minority faction in the UNION.”
Alternatively, peti­tioner contends that the industrial court’s assumption of
jurisdiction in this case would “set at naught the return-to-work
agreement … between the COMPANY and the UNION, impair
the obligation of an existing collective bargaining agreement . . . . . and
violate the Industrial Peace Act and weaken the system of free and voluntary
collective bargaining.” (p. 12, Petition)

As far as this Court is concerned, there can be no argument
against the validity and efficacy of the presidential certification here in
issue.  Petitioner argues that the President’s
action was issued on erron­eous factual bases. 
Whether it was so issued or not, this Court is not constitutionally
permitted to inquire into, in exactly the same manner that the Executive cannot
refuse to accord respect and sanction to a decision of this Court merely for
the reason that in his opinion the same is without sufficient factual or legal basis.  Otherwise, the principle of separation of
powers among the three great departments of our government, the legislative,
the executive and the judicial, with its necessary implications of independence
from and interdependence upon
each other, would be a myth wherein it is most likely that the judiciary would
be supreme, a role naturally to be relished but firmly not to be desired, if it
will cause the abandonment of a juridical and constitutional formula that has
served through the de­cades as the invulnerable bastion of individual liberties
as well as the indestructible cornerstone of the rule of law in this country.

As We
see it, the root issue of jurisdiction in this case related to the
validity of the challenged presi­dential certification cannot be resolved on
the factual premises assumed by the industrial court.  There is here a vital issue of fact, which
unfortunately, as stated at the outset of this opinion, the respondent court
omitted to resolve.  It is the question
of whether or not Juanito Tabuyan
and his co-signers of the disputed agreements were legitimate officers of the
respondent Union.

It will be recalled that petitioner’s principal ob­jection to the
assumption of jurisdiction by the respond­ent court was that there was no
longer any labor dispute which said court could arbitrate at the time of the
issu­ance of the presidential certification on October 22,1965 because as early
as October 14, 1965, petitioner Company and respondent Union had already forged
a return to work agreement that put an end to the strike declared by the latter
against the former in May of that year and that, furthermore, the parties were
already negotiating and were well on the way to formalizing a renewal of their
collective bargaining agreement which was due to expire on December 6, 1965,
as, in fact, such an agreement was signed by the Union and the Company on
December 23, 1965.  Putting aside the question
of whether or not the alleged return-to-work agreement of October 14th and the
claimed actual termination of the strike on said date should be considered as
having foreclosed the legality or propriety of the issuance of any presidential
certification of the dispute between petitioner and the respondent Union, it
being clear that compulsory arbitration may be certified by the President as
long as, in his opinion, a “labor dispute”, which this Court has
defined as “any contro­versy concerning the terms, conditions and tenure
of em­ployment,”^[1]
exists in an industry indispensable to the national interest, whether a strike
therein be impending, going on or already terminated without a final settlement
of the dispute, We are of the opinion that the conclusion of the negotiations
for a collective bargaining agreement on December 23, 1965, if entered into by
those properly authorized to do so, could have ousted the jurisdiction of the
CIR, except to determine whether or not said agree­ment was not contrary to
law, morals or public policy, in line with the dominant policy of the
Industrial Peace Act of favoring
unionism and free bargaining between labor and management as against compulsory
arbitration with go­vernmental intervention. 
(Section 1, Republic Act 875).  It
does not appear, however, that, although the petition­er’s motion for
reconsideration was still pending in the CIR at the time of the said agreement
on December 23, the same was brought to its attention, much less made the basis
of any pleading.

In other words, as matters stood in the respondent court when it
denied petitioner’s motion for reconsidera­tion, there was already signed
between the petitioner and, purportedly, the respondent Union a collective
bargaining agreement, and, if, contrary to the allegations of Atty. Bocobo, the persons who signed the same as officers of the
Union were the legitimate officers they represented them­selves to be, it would
be quite clear that the industrial court should have declared itself without
further basis or authority to continue trying to arbitrate between parties who
have already settled the differences between themsel­ves, precisely in the
manner sought to be encouraged and protected by the Industrial Peace Act – free
collective bargaining – or, it should have, at least, suspended the proceedings
until the decisive issue of who were the genuine and legitimate officers of the
Union had been set­tled by it.  If, as
contended by herein respondents, Jua­nito Tabuyan and the others who signed the agreement as officers
of the Union “had no right to represent the Union and the strikers”
(p. 5, Respondents’ Brief) and that the agreement signed by them “was
unauthorized, spurious, illegal and immoral, (p. 8, Id.) there can be no question that the jurisdiction and authority
of the respondent court remained unaffected by the said collec­tive bargaining
agreement relied upon by petitioner.  The
purpose of a presidential certification is nothing more than to bring about
soonest, thru arbitration by the industrial court, a fair and just solution of the differences
between an employer and his workers regarding the terms and conditions of work
in the industry concerned which in the opinion of the President involves the na­tional
interest, so that the damage such employer-worker dispute might cause upon the
national interest may be minimized as much as possible, if not totally averted by
avoiding the stoppage of work as a result of a strike or lock out or any lagging of
the activities of the industry or the possibility of these contingencies which
might cause detriment to such national interest.  This is the foundation of that court’s
jurisdiction in what may be termed as a certification case.  Naturally, if the employer and the workers
are able to arrive at an amicable settlement by free and voluntary collective
bargaining preferably thru a labor union, before the court is able to use its
good offices, it is but in consonance with the objective of the Industrial
Peace Act to pro­mote unionism and free collective bargaining that the court
should step out of the picture and declare its function in the premises at an
end, except as it may be­come necessary to determine whether or not the
agreement forged by the parties is not contrary to law, morals or public
policy.  This is clear from the terms of
Section 10 of the Act, from which the industrial court derives its jurisdiction
in a certification case, since it expressly provides that “the Court may
issue an order fix­ing the terms and conditions of employment”, “if
no other solution to the dispute is found.” Besides, a pre­sidential
certification to the industrial court automati­cally makes operative in regard
to the certified dispute all the provisions of Commonwealth Act 103 needed to
carry out the intent of said section of the Industrial Peace Act,^[2]
and among the provisions which so come into play is the second paragraph of
Section 4 which reads thus:

“The Court shall, before hearing the dispute and in the
course of such hearing, endeavor to reconcile the parties and induce them to
set­tle the dispute by amicable agree­ment. 
If any agreement as to the whole or any part of the dispute is arrived
at by the parties, a memo­randum of its terms shall be made in writing, signed
and acknowledged by the parties thereto before the Judge of the Court or any
official acting in his behalf and authorized to administer oaths or acknowledg­ments,
or, before a notary public.  The
memorandum shall be filed in the office of the Clerk of the Court, and, unless otherwise ordered by the Court,
shall, as between the parties to the agreement, have the same ef­fect as, and
be deemed to be, a deci­sion or award.”

Otherwise stated, in the case at bar, We need not decide whether
or not the return-to-work agreement of October 14, 1965 rendered the
presidential certification on October 22, 1965 factually and legally baseless
or inoperative.  Neither is it incumbent
upon Us to rule here whether or not a presidential certification once issued
can be withdrawn, and, consequently, whether or not the presidential certification
herein involved may be considered as withdrawn in view of the favorable re­commendation
to such effect by the Undersecretary of La­bor. 
All that We hold now is that the entering into a voluntary and valid
collective bargaining agreement between an employer and a labor union of its
workers before or after a presidential certification is issued under Section 10
of the Industrial Peace Act ousts the juris­diction of the Court of Industrial
Relations, except as to the question of whether or not the agreement is con­trary
to law, morals or public policy, should such ques­tion be raised by any of the
parties, and in this connec­tion and with respect to the laborers or workers,
whether the question be raised by the Union as such or by any of the members
thereof.

Petitioner contends that the workers represented by Atty. Bocobo constitute a mere “minority faction” and
as such they do not have legal personality to obstruct the course of the
return-to-work and collective bargaining agreements entered into by the
majority.  The trouble with this argument
is that except for the casual reference in the order of November 11, 1965 to
“200 others” which seem to
indicate the number of workers who did not return to work pursuant to the
return-to-work agreement of Octo­ber 14th, the record is remarkably bare of any
facts or evidence on which this Court may make a factual finding in connection
with the point raised by petitioner.  In any
event, the majority rule is not an absolute one in la­bor cases of this kind.^[3]
More importantly, as already indicated above, any number of members of a labor
union may question, in the appropriate cases, any agreement entered into by its officers or the majority if it is
contrary to law, morals or public policy. 
Thus, even if We do not consider respondents’ contention that strictly
speaking, the presidential certification here refers expressly not to the Union
but to the members thereof as being the ones having a dispute with petitioner,
a point which, to be sure, We cannot decide since there are not enough facts in
the record for the purpose, it is quite clear that the pivotal issue in this
case is the due representation of the Union in the collective bargaining
agreement in question.

Accordingly, what the respondent court should have determined was
whether or not Juanito Tabuyan
and the others who signed the agreements relied upon by petition­er, as
officers of respondent Union, were duly chosen by the
majority of the members as such.  After
this important factual point is decided, the respondent court may proceed to
resolve the rights of the parties in line with views expressed in the above
opinion.

WHEREFORE, the order of November 11, 1965 of re­spondent
court is affirmed in so far as it ordered the return to work of all the workers
of petitioner, except the 33 strikers who have been charged criminally, and
their acceptance by the petitioner, but this case is ordered returned to
respondent court for further proceed­ings in accordance with the above opinion
regarding the effect of the purported renewal collective bargaining agreement
of December 23, 1965 upon its jurisdiction ac­quired by virtue of presidential
certification.  Without
costs.

Concepcion, C.J., Reyes, J.B.L., Dizon,
Makalintal, Zaldivar, Castro, Fernando, Teehankee, Villamor, and Makasiar, JJ., concur.

^[1]
Caltex (Phil.) Inc. vs. Katipunan
Labor Union, L-7496, January 31, 1956,
98 Phil. 340.

^[2]
PAFLU vs. Tan, L-9115, Aug. 31, 1956, 52 O.G. 5836; National Garments
& Textiles Workers’ Union vs. Ca­luag,
L-9104, Sept. 10, 1956; Allied
Free Workers’ Union vs. Apostol, L-8876, Oct.
31, 1957, 54 O. G. 981; SMB Box Factory Worker’s Union vs. Victoriano, L-12820, Dec. 20, 1957; Benguet
Consolidated Mining Co. vs. Coto Labor Union,
L-12394, May 29, 1959; Chua Workers’ Union vs. City Automotive Co.,
L-11655, April 29, 1959; Rizal Cement Co. vs. Rizal Cement Workers’ Union,
L-12747, July 30, 1960; Rizal Cement Workers Union vs.
CIR, L-18442, Nov. 30, 1962.

^[3]
La Campana Food Products, Inc. vs. CIR,
L-27907, May 22, 1969, 28
SCRA 314; Heirs of Teodolo M. Cruz vs. CIR,
L-23331-32, Dec. 27,1969,
30 SCRA 917.