Automotive Industry Workers Alliance v.

Romulo
G.R. NO. 157509
January 18, 2005
Chico-Nazario, J.

SUBJECT MATTER:
Property Party (whether a party has standing or not)
Locus Standi or legal standing - standing to bring a case to Court; personal and substantial interest in the case such that the party has
sustained or will sustain direct injury as a result of the governmental act that is being challenged

DOCTRINE
Judicial Review - power of court to review Acts by Congress and the President to decide their constitutionality
1. existence of an appropriate case
2. interest personal and substantial by the party raising the constitutional question
3. plea that the function be exercised at the earliest opportunity
4. necessity that the constitutional question be passed upon in order to decide the case

ACTION BEFORE THE SUPREME COURT:

Ex. PETITION to review the decision of the Executive Assistant to the President.

Petitioner(s): Automotive Industry Workers Alliance (Mitsubishi Motors Workers Phils. Union; Mitsubishi Motors
Parties Phils. Supervisors Union, Nissan Motors Phils., Inc. Workers Union, Toyota Motors Phils. Workers
Union, DURASTEEL WORKERS UNION, FILSHUTTERS EMPLOYEES & WORKERS UNION, NATIONAL
LABOR UNION, PEPSI-COLA SUPERVISORS AND EMPLOYEES UNION, PSBA FACULTY ASSOCIATION,
PLDT SECURITY PERSONNEL UNION, PUREFOODS UNIFIED LABOR ORGANIZATION, SAMAHANG
MANGGAGAWA NG BICUTAN CONTAINERS CORP., SAMAHANG MANGGAGAWA NG CINDERELLA,
SAMAHANG MANGGAGAWA NG LAURA'S FOOD PRODUCTS)

Respondent(s): Executive Secretary Alberto Romulo, Secretary of Labor and Employment Patricia Sto. Tomas

SUMMARY:
Petitioners sought judicial review to declare an executive order unconstitutional for violating the doctrine of separation of powers.

Invoking their rights as labor union and taxpayers, Automotive Industry Workers Alliance (AIWA) petitioned Executive Order No. 185
be declared void. EO 185 transferred supervision of National Labor Relations Commission (NLRC) from NLRC Chairman to DOLE
Secretary. Petitioner argued that EO 185 repeals RA 6715, declaring NLRC be under DOLE for program and policy coordination ONLY.

Office of Solicitor General opposed the petition for procedural and substantive grounds. (Procedural grounds) Petitioner did not
specify how EO 185 will affect their rights as labor union and taxpayers, and they have no standing since labor unions are exempt
from paying taxes AND even if they are taxpayers as individuals, EO 185 does not need taxpayers money to be implemented.
(Substative grounds) Additionally, NLRC and DOLE are under the broader powers of the President as provided by Section 17, Article
VII.

Petitioner replied that they represent 50,000 workers as well as those workers with pending cases in NLRC.

Court decided that AIWA has no standing to seek judicial review. Court didn't answer whether EO 185 is constitutional or not.

ANTECEDENT FACTS:
● History of NLRC: NLRC was created by PD 442, otherwise known as Labor Code, during Martial Law era. PD 442 said that
NLRC was an integral part of DOLE, but under the supervision of DOJ Secretary. Having legislative power post-EDSA, Pres.
Aquino transferred administrative supervision of NLRC to DOLE through EO 292. FINALLY, RA 6715 amended the Labor Code
and transferred administrative supervision of NLRC to NLRC Chairman, and left program and policy coordination to DOLE.
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 EO 185 reverted the supervision of NLRC to DOLE Secretary.
● NLRC is a quasi-judicial agency that resolves labor and management disputes for local and overseas workers.
● For judicial review issues, the standing of petitioner is almost always questioned first.

ISSUE(S) AND HOLDING(S):

1. W/N Automotive Industry Workers Alliance have the standing to assail the Executive Order? -- NO.

RATIO:
1. A prerequisite of judicial review is that the party seeking the review of a statute should have suffered some actual or
threatened injury. Petitioner failed to show such. However, an NLRC personnel, being subject to disciplinary authority of
DOLE Secretary, can file such petition. Meanwhile, on the topic of encroachment of constitutionally mandated power, only
Congress could file such petition.

DISPOSITIVE:
WHEREFORE, premises considered, the instant petition dated 27 March 2003 is hereby DISMISSED for lack of merit. No costs.

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