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Planters Association of Negros, Inc. v.

Ponferrada, supra

TOPIC: IV. AIDS IN STATUTORY CONSTRUCTION


A. Public Policy sought to be implemented

FACTS:

 On May 24, 1991, Republic Act No. 6982, entitled “An Act Strengthening the Sugar Amelioration
Program in the Sugar Industry, Providing the Mechanics for its Implementation, and for other
Purposes”, took effect.

 RA 6982 imposed a lien of P5.00 per picul on all sugar produced beginning sugar crop year
1991-1992, with an automatic additional lien of P1.00 for every two (2) years for the succeeding
ten (10) years from the said effectivity of the Act to the discretion of the Secretary of Labor and
Employment and upon recommendation of the Sugar Tripartite Council.

 However, prior to the of passage of RA 6982, Republic Act No. 809 and Presidential Decree No.
621 were the two principal laws providing additional benefits to sugar farm workers.

 Thus, before R.A. No. 6982, there were two sets of beneficiaries under the social amelioration
program in the sugar industry:

1) Beneficiaries under R.A. No. 809 and P.D. No. 621; and

2) Beneficiaries under P.D. No. 621 only. (In milling districts where the annual gross
production is less than 150,000 piculs)

 To address the effect of the new P5.00 per picul lien, Section 12 of R.A. No. 6982, hereby
substituted the benefits under the two previously existing laws, however it does not cover those
pending cases from such laws, thus shall not be affected from the time of its effectivity.

 Section 14 of the same Act further states the non-diminution of benefits of the sugar workers
which shall not be construed to reduce any benefit, interest, right or participation enjoyed by the
workers and there would be no amount received by any beneficiary be subject to any form of
taxation.

 For crop year 1991-1992, the sugar farm workers' share in Binalbagan — Isabela Sugar
Company (BISCOM) under R.A. No. 809 was P30,590,086.92 and under P.D. No. 621 was
P2,233;258.26, or with a total amount of P32,823,345.18. On the other hand, with the
implementation of R.A. 6982, the total workers' benefit in BISCOM milling district was only
P5,583,145.61.

 Meantime, pending a definite ruling on the effect of R.A. No. 6982 to R.A. No. 809 and P.D. No.
621, the Secretary of Labor issued Department Order (D.O.) No. 2 (1992) directing, among
others, the three milling district in Negros Occidental to continue implementing R.A. No. 809 per
recommendation of the Sugar Tripartite Council.

 Consequently, the Planters Association of Southern Negros, Inc. (PASON) as an organization of


sugar farm plantation owners milling with BISCOM filed with the Court a Petition for Declaratory
Relief against the implementation of the said D.O. No. 2.
ISSUE:

Whether or not R.A. No. 6982 did not and cannot supersede or substitute the benefits under
R.A. No. 809.

THESIS:

Yes, R.A. No. 6982 did not and cannot supersede or substitute the benefits under R.A. No.
809.

RULE:

Consequently, laws are given a reasonable construction such that apparently conflicting
provisions are allowed to stand and given effect by reconciling them, reference being had to the
moving spirit behind the enactment of the statute. Apparently conflicting provisions should be
construed as to realize the purpose of the law. Thus, between two statutory interpretations, that
which better serves the purpose of the law should prevail.

ANALYSIS:

In this case, the Court ruled that the addition of the monetary rewards under R.A. No. 6982 to the
benefits granted by R.A. 809, is what is called for in the case under consideration. While it is true
that "addition" is different from "substitution", the circumstances involving subject milling districts
(where the sugar farm workers are enjoying benefits both from R.A. 809 .and P.D. No. 621 prior to
the effectivity of R.A. No. 6982), necessitate the grant of pecuniary advantage under R.A. No. 809 as
a complement to R.A. No. 6982. Otherwise, the workers would suffer a diminution of benefits.
Therefore, the increase of monetary advantage in favor of the sugar farm workers, as a
consequence of such interpretation, is merely incidental to the application of the non-diminution
policy of R.A. No. 6982, a labor provision which should be liberally construed to further its purpose.
Certainly, such a disadvantageous construction cannot be countenanced, being violative of the non-
diminution principle under Section 14 of R.A. No. 6982.

Accordingly, neither does the Court find convincing the interpretation proposed by private
respondent BISCOM. While maintaining the application of R.A. No. 809 and P.D. No. 621 (where the
total share of the workers is P32,823,345.18), and disregarding R.A. No. 6892, would be beneficial
to the sugar farm workers, to the mind of the Court, the assailed construction of the public
respondent (where the total share of the workers is P36,173,232.53), would be more in keeping with
the spirit of R.A. No. 6982 which is: to improve the living condition of workers in the sugar industry.
Between two statutory interpretations, that which better serves the purpose of the law should prevail.

The Court is of the ineluctable conclusion, and so holds, that the respondent Court ventured not in
any judicial legislation but merely gave life to the avowed policy of the State under Section 18, Article
2 of the 1987 Constitution, which states:

 Sec. 18. The state affirms labor as a primary social economic force. It shall guarantee the
rights of workers and promote their welfare.
CONCLUSION:

Thus, R.A. No. 6982 did not and cannot supersede or substitute the benefits under R.A. No.
809.

FULL TEXT REFERENCE:


https://lawphil.net/judjuris/juri1999/oct1999/gr_114087_1999.html#rnt19

NOTES:

Republic Act No. 809 (implementable in milling districts with an annual gross production of 150,000
piculs or more), institutionalized production sharing scheme, in the absence of any private
agreement between the planters and farm workers, depending on the mill's total production for each
immediately preceding crop year; and specifically providing that any increase in the planters' share
shall be divided in the following manner: 40% of the increase shall accrue to the planter and 60% to
the farm workers.

Presidential Decree No. 621, as amended, charged a lien of P2.00 per picul on all sugar produced,
to be pooled into a fund for subsequent distribution as bonuses to sugar workers.

Section 12 of R.A. No. 6982, provides:

Sec. 12. Benefits under Republic Act No. 809 and P.D. 621, as Amended. — All liens and other
forms of production sharing in favor of the workers in the sugar industry under Republic Act No. 809
and Presidential Decree No. 621, as amended, are hereby substituted by the benefits under this Act:
Provided, That cases arising from such laws pending in the courts or administrative bodies at the
time of the effectivity of this Act shall not be affected thereby.

Section 14 of R.A. No. 6982, provides:

Sec. 14. Non-Diminution of Benefits. — The provisions of Section 12 hereof notwithstanding, nothing
in this Act shall be construed to reduce any benefit, interest, right or participation enjoyed by the
workers at the time of the enactment of this Act, and no amount received by any beneficiary under
this Act shall be subject to any form of taxation.

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