GUIDO vs. RURAL PROGRESS
The expropriation by the respondent is violative
ADMINISTRATION (G.R. No. L-2089 Oct. 31,
1949)
FACTS:
This a petition for prohibition to prevent the Rural
Progress Administration and Judge Oscar Castelo of
the Court of First Instance of Rizal from proceeding
with the expropriation of the petitioner Justa G.
Guido's land. One of the grounds raised by the
petitioner was that "the land sought to be expropriated
is commercial and therefore excluded within the
purview of the provisions of Act 539."
Sections 1 and 2 of Commonwealth Act No. 539,
copied verbatim, are as follows:
SECTION 1. The President of the Philippines is
authorized to acquire private lands or any interest
therein, through purchaser or farms for resale at
reasonable prices and under such conditions as he may
fix to their bona fide tenants or occupants or to private
individuals who will work the lands themselves and
who are qualified to acquire and own lands in the
Philippines.
SEC. 2. The President may designated any department,
bureau, office, or instrumentality of the National
Government, or he may organize a new agency to carry
out the objectives of this Act. For this purpose, the
agency so created or designated shall be considered a
public corporation.
The National Assembly approved this enactment on
the authority of section 4 of Article XIII of the
Constitution which, copied verbatim, is as follows:
The Congress may authorize, upon payment of just
compensation, the expropriation of lands to be
subdivided into small lots and conveyed at cost to
individuals.
What lands does this provision have in view? Does it
comprehend all lands regardless of their location,
nature and area? According to Mr. Cuaderno " If we
are to be true to our trust, if it is our purpose in drafting
our constitution to insure domestic tranquility and to
provide for the well-being of our people, we cannot,
we must fail to prohibit the ownership of large estates,
to make it the duty of the government to break up
existing large estates, and to provide for their
acquisition by purchase or through expropriation and
sale to their occupants, as has been provided in the
Constitutions of Mexico and Jugoslavia"
ISSUE:
Whether or not the petitioner has been deprived of the
principle of social justice.
HELD:
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Yes.
of the priniciple of social justice. "The promotion of
social justice to insure the well-being and economic
security of all the people should be the concern of the
state." The Philippines as a Republican state embraces
as its necessary components freedom of conscience,
freedom of expression, and freedom in the pursuit of
happiness. Along with these freedoms are included
economic freedom and freedom of enterprise within
reasonable bounds and under proper control.
The promotion of social justice ordained by the
Constitution does not supply paramount basis for
untrammeled expropriation of private land by the
Rural Progress Administration or any other
government instrumentality. Social justice does not
champion division of property or equality of economic
status; what it and the Constitution do guaranty are
equality of opportunity, equality of political rights,
equality before the law, equality between values given
and received on the basis of efforts exerted in their
production
CABATAN vs CA (G.R. No. L-44875 Jan. 22, 1980)
FACTS:
The foregoing rentals in tobacco and/or cash for palay
harvest were arrived at or mutually agreed upon by the
land owner and/or her predecessors and the respective
tenants and/or their predecessors, before the enactment
of the Tenancy Act fixing rentals on agri-tenanted
holdings. The holdings are devoted to the planting of
palay, sometimes corn, and tobacco alternately within
the calendar year. Palay is planted in May-June and
harvested in September-October; while tobacco is
planted in November-December and harvested in
February-March of the following year. The tenancy
agreements were renewable each calendar year.
The hacienda, devoted mainly to production of native
tobacco, is for the most part not irrigated but is
dependent mainly on rainfull for water. However, the
landholdings of petitioner tenants in CAMACHO,
DACLAN, HERRERIA PANELO, MELANA and
MARQUEZ were benefited by the construction of the
canals by the National Irrigation Administration (NIA)
sometime in January 1975.
Sometime in March, 1971, before the palay planting
season, plaintiff through her son demanded from the
defendants-tenants, they shall pay a fixed rental in kind
equivalent to the normal harvest of each crop of palay
or tobacco for the three agri-years in accordance with
Sec. 34. The defendants-tenants rejected the plaintiff's
demand and instead offered to pay the same annual
rentals or that which they have been paying prior to
1971-72. The landholder in turn refused to accept the
tenants' counter offer. The lease rentals which the
tenants were paying are not equivalent to or less than
25% of the average normal net harvest from the
landholdings of the past three agri-years immediately
prior to 1971-72 and therefore were found by the CAR
to be unfair/unjust to the landholder. In view of the
failure to agree as to the rental rates, the landholder
filed the Petitions with the Court of Agrarian Relations
(CAR).
The CAR, per Judge Arturo V. Malazo, denied the
landholders' petition for ejectment but consistent
upheld her right to have the rental rates fixed in
accordance with the provisions of RA 3844, as
amended by RA 6389, that is, a rental rate equivalent
to the average of the normal net harvest of the past
three agri-years. On appeal, as adverted to earlier, the
Court of Appeals thru the 6th Division affirmed the
CAR's judgment fixing the rental rates.
ISSUE:
Whether or not CAR justly upheld its right to fixed
rental rates in accordance with RA 3844 as ammended
by RA 6389.
HELD:
Yes. The court affirmed the CAR's decision in toto.
The CAR is hereby authorized to determine and fix the
rentals on the basis of rot more than 25% of the average
normal harvest for three (3) agri-years for both tobacco
and palay crops. The brief for the tenants-lessees in
turn rely upon the thesis that Sec. 34 is a social justice
legislation aimed "...to redeem the tenants from
misery, want and oftentimes oppression arising from
the onerous terms of his tenancy." That a rental
agreement voluntarily entered into is presumed valid
and the party who questions its validity has the burden
to show that it is not conformable to law or is not
reasonable and just. That the rental now being paid by
the tenants is beneficial or advantageous to them
because the same is less than 25% of the average
harvest.
Social justice as thus defined and in its true meaning is
not meant to countenance, much less perpetuate, an
injustice against any group — not even as against
landholders. For the landholders as a component unit
or element in our agro-industrial society are entitled to
"equal justice under law" which our courts are, above
everything else, under mandate of the Constitution to
dispense fairly, without fear nor favor.
PLDT vs. NLRC (G.R. No. L-80609 Aug. 23, 1988)
FACTS:
Marilyn Abucay, a traffic operator of the Philippine
Long Distance Telephone Company, was accused by
two complainants of having demanded and received
from them the total amount of P3,800.00 in
consideration of her promise to facilitate approval of
their applications for telephone installation.
Investigated and heard, she was found guilty as
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charged and accordingly separated from the service.
She went to the Ministry of Labor and Employment
claiming she had been illegally removed. After
consideration of the evidence and arguments of the
parties, the company was sustained and the complaint
was dismissed for lack of merit. The decision is as
follows:
Considering that Dr. Helen Bangayan and Mrs.
Consolacion Martinez are not totally blameless in the
light of the fact that the deal happened outside the
premises of respondent company and that their act of
giving P3,800.00 without any receipt is tantamount to
corruption of public officers, complainant must be
given one month pay for every year of service as
financial assistance.
Both the petitioner and the private respondent
appealed to the National Labor Relations Board, which
upheld the said decision in toto and dismissed the
appeals. The private respondent took no further action,
thereby impliedly accepting the validity of her
dismissal. Hence, this petition.
ISSUE:
Whether or not the giving of one month separation pay
is in conformity with social justice.
HELD:
No. It is conceded that an employee illegally dismissed
is entitled to reinstatement and backwages as required
by the labor laws. However, an employee dismissed
for cause is entitled to neither reinstatement nor
backwages and is not allowed any relief at all because
his dismissal is in accordance with law. The rule
embodied in the Labor Code is that a person dismissed
for cause as defined therein is not entitled to separation
pay. We hold that henceforth separation pay shall be
allowed as a measure of social justice only in those
instances where the employee is validly dismissed for
causes other than serious misconduct or those
reflecting on his moral character. Where the reason for
the valid dismissal is, for example, habitual
intoxication or an offense involving moral turpitude,
like theft or illicit sexual relations with a fellow
worker, the employer may not be required to give the
dismissed employee separation pay, or financial
assistance, or whatever other name it is called, on the
ground of social justice.
The policy of social justice is not intended to
countenance wrongdoing simply because it is
committed by the underprivileged.Those who invoke
social justice may do so only if their hands are clean
and their motives blameless and not simply because
they happen to be poor. This great policy of our
Constitution is not meant for the protection of those
who have proved they are not worthy of it, like the
workers who have tainted the cause of labor with the
blemishes of their own character.Applying the above
considerations, we hold that the grant of separation pay
in the case at bar is unjustified. The private respondent
has been dismissed for dishonesty, as found by the
labor arbiter and affirmed by the NLRC and as she
herself has impliedly admitted. The fact that she has
worked with the PLDT for more than a decade, if it is
to be considered at all, should be taken against her as
it reflects a regrettable lack of loyalty that she should
have strengthened instead of betraying during all of her
10 years of service with the company.
UST vs NLRC (182 SCRA 371 1992)
FACTS:
University of Sto. Tomas (UST) terminated the
employment of 16 union officers and directors of UST
Faculty Union for grave misconduct, serious
disrespect to a superior and conduct unbecoming a
faculty member on the ground that "in publishing or
causing to be published in Strike Bulletin No. 5 the
libelous and defamatory attacks against the Father
Rector. Some faculty members staged mass leaves of
absence disrupting classes in all levels at the
University. The faculty union filed a complaint for
illegal dismissal and unfair labor practice with the
DOLE. The labor arbiter, on a prima facie showing
that the termination was causing a serious labor
dispute, certified the matter to the Secretary of DOLE
for a possible suspension of the effects of termination.
Secretary Franklin Drilon issued an order to accept the
16 terminated employess back to work under the same
terms and conditions prevailing prior to their dismissal
in the interest of industrial peace. Secretary Drilon
issued another order which certifies the labor dispute
to the NLRC for compulsory arbitration. NLRC issued
a resolution directing UST to comply and faithfully
abide with the Orders of the Secretary Drilon by
immediately reinstating or readmitting the 16 faculty
members under the same terms and conditions
prevailing prior to the present dispute or merely
reinstate them in the payroll. UST states that it has
already actually reinstated 6 of the dismissed faculty
members; As to 2 professors whose teaching
assignments were partially taken over by new faculty
members, they were given back their remaining
teaching loads (not taken by new faculty members) but
were given substantially equivalent academic
assignments corresponding to their teachings loads
already taken over by new faculty members; The
remaining 7 faculty members were given substantially
equivalent academic assignments in lieu of actual
teaching loads because all of their teaching loads
originally assigned to them at the start of the first
semester were already taken over by new faculty
members; 1 dismissed faculty had been "absent
without official leave" or AWOL. SC issued a TRO
enjoining NLRC from enforcing or executing the
NLRC resolution. UST argues that actual
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reinstatement of the dismissed faculty members whose
teaching assignments were previously taken over by
new faculty members is not feasible nor practicable
since this would compel UST to violate and terminate
its contracts with the faculty members who were
assigned to and had actually taken over the courses.
UST claims that to change the faculty member when
the semester is about to end would seriously impair
and prejudice the welfare and interest of the students
because dislocation, confusion and loss in momentum,
if not demoralization will surely ensue. UST
contended that it has the sole and exclusive right and
prerogative to determine the nature and kind of work
of its employees and to control and manage its own
operations
ISSUE:
May UST comply with the NLRC readmission order
by granting substantially equivalent academic
assignments, in lieu of actual reinstatement, to
dismissed faculty members?
HELD:
No. Pursuant to Article 263 (g), 1st paragraph, of the
Labor Code, as amended by Section 27 of RA 6715,
the NLRC was charged with the task of implementing
a valid return-to-work order of the Secretary of Labor.
As the implementing body, its authority did not
include the power to amend the Secretary's order.
Since the Secretary's order specifically provided that
the dismissed faculty members shall be readmitted
under the same terms and conditions prevailing prior
to the present dispute, the NLRC should have directed
the actual reinstatement of the concerned faculty
members. It therefore erred in granting the alternative
remedy of payroll reinstatement. The grant of
substantially equivalent academic assignments cannot
be sustained. The giving of substantially equivalent
academic assignments, without actual teaching loads,
cannot be considered a reinstatement under the same
terms and conditions prevailing before the strike. The
phrase "under the same terms and conditions"
contemplates actual reinstatement or the return of
actual teaching loads to the dismissed faculty
members. Article 263(g) was devised to maintain the
status quo between the workers and management in a
labor dispute causing or likely to cause a strike or
lockout in an industry indispensable to the national
interest,pending adjudicationof the controversy. The
grant of substantially equivalent academic
assignments would evidently alter the existing status
quo since the temporarily reinstated teachers will not
be given their usual teaching loads. The order of
NLRC did not amount to grave abuse of discretion.
Such error is merely an error of judgment which is not
correctible by a special civil action for certiorari. The
NLRC was only trying its best to work out a
satisfactory ad hoc solution to a festering and serious
problem. The hiring, firing, transfer, demotion and
promotion of employees are traditionally identified as
management prerogatives. However, these are not
absolute prerogatives. They are subject to limitations
found in law, a collective bargaining agreement, or
general principles of fair play and justice. Article
263(g) is one such limitation provided by law. To the
extent that Art. 263(g) calls for the admission of all
workers under the same terms and conditions
prevailing before the strike, UST is restricted from
exercising its generally unbounded right to transfer or
reassign its employees. The first semester is about to
end and to change the faculty members around the time
of final examinations would adversely affect and
prejudice the students whose welfare and interest we
consider to be of primordial importance and for whom
both the University and the faculty union must
subordinate their claims and desires. The actual
reinstatement of the non-reinstated faculty members
may take effect at the start of the second semester. The
contracts of new professors cannot prevail over the
right to reinstatement of the dismissed personnel.
Petition is denied.
UST vs NLRC *not sure* kulang
FACTS:
On June 19, 1989, the University of Sto. Tomas (UST),
through its Board of Trustees, terminated the
employment of all sixteen union officers and directors
of respondent UST Faculty Union on the ground that
"in publishing or causing to be published in Strike
Bulletin No. 5 dated August 4, 1987, the libelous and
defamatory attacks against the Father Rector, (each of
them) has committed the offenses of grave
misconduct, serious disrespect to a superior and
conduct unbecoming a faculty member." On July 5,
1989, the faculty union filed a complaint for illegal
dismissal and unfair labor practice with the
Department of Labor and Employment. The
termination of the employees was causing a serious
labor dispute, certified the matter to the Secretary of
Labor and Employment for the possible suspension of
termination.
Sec. Franklin Drilon issued the order for the
termination of suspension. UST filed a motion for
reconsideration asking Drilon to assume jurisdiction or
certify it to the NLRC. Sec. Drilon issued the second
order modifying the first order, it was certified to
NLRC. Sec. Drilon issued another order directing the
readmission of all faculty members. The respondent
filed at the NLRC a motion to implement the orders of
the Secretary. the NLRC issued a resolution, which is
the subject of this petition for certiorari.
The petitioner advances the argument that its grant of
substantially equivalent academic assignments to
some of the dismissed faculty members, instead of
actual reinstatement, is well-supported by just and
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valid reasons. It alleges that actual reinstatement of the
dismissed faculty members whose teaching
assignments were previously taken over by new
faculty members is not feasible nor practicable since
this would compel the petitioner university to violate
and terminate its contracts with the faculty members
who were assigned to and had actually taken over the
courses.
Acting on an urgent motion for the issuance of a writ
of preliminary injunction and/or restraining order, the
Court resolved to issue a temporary restraining order
dated October 25, 1989 enjoining respondents from
enforcing or executing the assailed NLRC resolution.
DOLE vs. PAMAO (G.R. No. 146650 Jan. 13, 2003)
FACTS:
On February 22, 1996, a new five-year Collective
Bargaining Agreement for the period starting February
1996 up to February 2001, was executed by petitioner
Dole Philippines, Inc., and private respondent Pawis
Ng Makabayang Obrero-NFL (PAMAO-NFL).
Among the provisions of the new CBA is the disputed
section on meal allowance under Section 3 of Article
XVIII on Bonuses and Allowances, which reads:
Section 3. MEAL ALLOWANCE. The COMPANY
agrees to grant a MEAL ALLOWANCE of TEN
PESOS (P10.00) to all employees who render at least
TWO (2) hours or more of actual overtime work on a
workday, and FREE MEALS, as presently practiced,
not exceeding TWENTY FIVE PESOS (P25.00) after
THREE (3) hours of actual overtime work.
Pursuant to the above provision of the CBA, some
departments of Dole reverted to the previous practice
of granting free meals after exactly three hours of
actual overtime work. However, other departments
continued the practice of granting free meals only after
more than three hours of overtime work. Private
respondent filed a complaint. The parties agreed to
submit dispute to voluntary arbitration. The voluntary
arbitration rendered an order in favor of private
respondent. Petitioner sought for a motion for
reconsideration but was denied. On appeal, the CA
upheld the order, hence this instant petition.
ISSUE:
Whether the DOLE commits a violation for not giving
their employees a free meal after rendering 3 hours of
work as stipulated in the CBA?
HELD:
Yes.The CBA states (in the facts). The exercise of
management prerogative is not unlimited. It is subject
to the limitations found in law, a collective bargaining
agreement or the general principles of fair play and
justice.9 This situation constitutes one of the
limitations. The CBA is the norm of conduct between
petitioner and private respondent and compliance
therewith is mandated by the express policy of the law.
Petitioner Dole cannot assail the voluntary arbitrator’s
interpretation of the CBA for the supposed impairment
of its management prerogatives just because the same
interpretation is contrary to its own.
GANDARA MILL SUPPLY vs NLRC (G.R. No.
126703 Dec. 29, 1998)
FACTS:
On February 6, 1995, Silvestre Germano, without
notifying his employer, Milagros Sy, did not report for
work until February 11, 1995 for he chose to be near
his wife who was then about to deliver. The wife gave
birth on February 12, 1995. Upon Silvestre's (private
respondent) request, Milagros Sy extended some
financial assistance to the Germano couple. Two (2)
weeks after, private respondent returned to duty, and
to his surprise, he was met by his employer to
personally tell him that someone had been hired to take
his place. He was advised, however, that he was to be
re-admitted in June 1996.K
On February 27, 1995, a case of illegal dismissal was
commenced by the private respondent with the
Department of Labor and Employment. The petitioner
then offered private respondent P5,000.00 but was
rejected. The Labor Arbiter directed the parties to
submit their position papers but petitioner failed to
comply, prompting the Labor Arbiter to render
decision ordering Gandara the sum of P65,685.90 in
favor of private respondent.
ISSUE:
Whether or not the private respondent was illegally
dismissed?
HELD:
Yes. After a careful study, and a thorough examination
of the pleadings and supporting documents, it appears
decisively clear that private respondent Silvestre
Germane was illegally dismissed. While a prolonged
absence without leave may constitute as a just cause of
dismissal, its illegality stems from the non-observance
of due process. While it cannot be deduced unerringly
from the records on hand that private respondent was
really dismissed, there is no clear indication that the
latter was to be reinstated. In fact, since the inception
of the case, what petitioner merely endeavored was to
compromise for a measly sum of P5,000.00, and no
mention of taking respondent back to his job was ever
offered as part of the deal to end the controversy.
Granting arguendo that private respondent's absence
engendered undue difficulty to the smooth operations
of petitioner's business, considering the predicament of
respondent Silvestre Germane, his dismissal is
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unwarranted. In holding the constitutional mandate of
protection to labor, the rigid rules of procedure may
sometimes be dispensed with to give room for
compassion. The doctrine of "compassionate justice"
is applicable under the premises, private respondent
being the breadwinner of his family. "The Social
Justice policy mandates a compassionate attitude
toward the working class in its relation to
management.
IMASEN PHIL. MANUFACTURING CORP. vs.
RAMONCHITO ALCON and JOANA S. PAPA
(G.R. No. 194884 Oct. 22, 2014)
FACTS:
Imasen Philippine Manufacturing Corporation is a
domestic corporation engaged in the manufacture of
auto seat-recliners and slide-adjusters. It hired the
respondents as manual welders in 2001. On October 5,
2002, the respondents reported for work on the second
shift. At around 12:40 am, Cyrus A. Altiche, Imasen’s
security guard on duty, went to patrol and inspect the
production plant’s premises. When Altiche reached
Imasen’s Press Area, he heard the sound of a running
industrial fan. Intending to turn the fan off, he followed
the sound that led him to the plant’s "Tool and Die"
section and saw the respondents having sexual
intercourse on the floor, using a piece of carton as
mattress. Altiche immediately went back to the guard
house and relayed what he saw to Danilo S. Ogana,
another security guard on duty. When Ogana made a
follow up inspection but saw several employees
including respondents leaving the area. Altiche then
submit a report.
Imasen issued respondents interoffice memoranda
informing them of the report and directing them to
submit explanation but the respondent deny the report.
Imasen then send another interoffice memorandum
directing them to appear at the formal hearing. Imasen
then issued a memoranda terminating their services It
found the respondents guilty of the act charged which
it considered as "gross misconduct contrary to the
existing policies, rules and regulations of the
company."
Respondents filed a complaint for illegal dismissal at
LA but was dismissed for lack of merit. NLRC
affirmed the LA's decision. On appeal, the CA
nullified the ruling of the NLRC and reduced the
penalty to three month suspension. Hence, this
petition.
ISSUE:
Whether the respondents’ infraction – engaging in
sexual intercourse inside company premises during
work hours – amounts to serious misconduct within the
terms of Article 282 (now Article 296) of the Labor
Code justifying their dismissal.
HELD:
Yes. The respondents’ infraction amounts to serious
misconduct within the terms of Article 282 (now
Article296) of the Labor Code justifying their
dismissal. Dismissal situations (on the ground of
serious misconduct) involving sexual acts, particularly
sexual intercourse committed by employees inside
company premises and during workhours, are not
usual violations and are not found in abundance under
jurisprudence.
In protecting the rights of the workers, the law,
however, does not authorize the oppression or self-
destruction of the employer. The constitutional
commitment to the policy of social justice cannot be
understood to mean that every labor dispute shall
automatically be decided in favor of labor. The
constitutional and legal protection equally recognize
the employer’s right and prerogative to manage its
operation according to reasonable standards and norms
of fair play.
Accordingly, except as limited by special law, an
employer is free to regulate, according to his own
judgment and discretion, all aspects of employment,
including hiring, work assignments, working methods,
time, place and manner of work, tools to beused,
processes to be followed, supervision of workers,
working regulations, transfer of employees, worker
supervision, layoff of workers and the discipline,
dismissal and recall of workers. As a general
proposition, an employer has free reign over every
aspect of its business, including the dismissal of his
employees as long as the exercise of its management
prerogativeis done reasonably, in good faith, and in a
manner not otherwise intended to defeat or circumvent
the rights of workers.
PEREZ and DORIA vs. PHIL. TELEGRAPH and
TELEPHONE COMPANY and Jose Santiago
(G.R. No. 152048 April 7, 2009)
FACTS:
Petitioners Felix B. Perez and Amante G. Doria were
employed by respondent Philippine Telegraph and
Telephone Company (PT&T) as shipping clerk and
supervisor, respectively, in PT&T’s Shipping Section,
Materials Management Group. Acting on an alleged
unsigned letter regarding anomalous transactions at
the Shipping Section, respondents formed a special
audit team to investigate the matter. It was discovered
that the Shipping Section jacked up the value of the
freight costs for goods shipped and that the duplicates
of the shipping documents allegedly showed traces of
tampering, alteration and superimposition.
On September 3, 1993, petitioners were placed on
preventive suspension for 30 days for their alleged
involvement in the anomaly. Their suspension was
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extended for 15 days twice: first on October 3, 19932
and second on October 18, 1993. Petitioners was then
dismissed from service. Petitioners filed a complaint
for illegal dismissal. The Labor Arbiter found that the
30-day extension of petitioners’ suspension and their
subsequent dismissal were both illegal.The National
Labor Relations Commission (NLRC) reversed the
decision of the labor arbiter. It ruled that petitioners
were dismissed for just cause, that they were accorded
due process and that they were only suspended for 15
days. Petitioners appealed to the CA and the CA
affirmed the NLRC decision insofar as petitioners’
illegal suspension for 15 days and dismissal for just
cause were concerned. Petitioners now seek a reversal
of the CA decision. They contend that there was no just
cause for their dismissal.
ISSUE:
Whether the dismissal of the petitioners is accorded
with just cause.
HELD:
No. find respondents’ evidence insufficient to clearly
and convincingly establish the facts from which the
loss of confidence resulted. The alterations on the
shipping documents could not reasonably be attributed
to petitioners because it was never proven that
petitioners alone had control of or access to these
documents. The burden of proof rests on the employer
to establish that the dismissal is for cause in view of
the security of tenure that employees enjoy under the
Constitution and the Labor Code. The employer’s
evidence must clearly and convincingly show the facts
on which the loss of confidence in the employee may
be fairly made to rest.It must be adequately proven by
substantial evidence. Respondents failed to discharge
this burden. A liberal interpretation of Art. 277(b) of
the Labor Code would be in keeping with Art. XIII of
the Constitution which dictates the promotion of social
justice and ordains full protection to labor. The basic
tenet of social justice is that "those who have less in
life must have more in law." Social justice commands
the protection by the State of the needy and the less
fortunate members of society.