Free Telephone Workers Union vs Minister of Labor

108 SCRA 757 Political Law Delegation of Power Completeness Test

FACTS: In 1981, there was an ongoing labor dispute between the Free Telephone
Workers Union (the Union) and the Philippine Long Distance Company. Eventually, the
Minister of Labor (Blas Ople) assumed jurisdiction over the issue pursuant to Article
264 of the Labor Code. The Union assailed the provisions of Article 264 as it averred
that it is an undue delegation of power by Congress to the Minister of Labor. They
averred that by granting discretion to the Minister of Labor to whether or not refer a
labor dispute for compulsory arbitration to the National Labor Relations Commission,
it also effectively granted the Minister to make or unmake the law on free collective
bargaining.

ISSUE: Whether or not such provision is an undue delegation of power.

HELD: No. In the first place, this issue is not yet ripe for adjudication as the Minister
of Labor was yet to take on the entirety of the case. There is still no ground to rule
that there is an unconstitutional application of the law.

The Union failed to make out a case of undue delegation of legislative power. There
could be, however, an unconstitutional application. For while the Constitution allows
compulsory arbitration, it must be stressed that the exercise of such competence
cannot ignore the basic fundamental principle and state policy that the state should
afford protection to labor. But as to whether or not there is an unconstitutional
application of the law, that is yet to be determined since the Minister of Labor has not
yet made a factual determination of the labor dispute in issue.

There is no undue delegation in this case. The law in issue is complete and it set a
sufficient standard. The law cannot be any clearer, the coverage being limited to
strikes or lockouts adversely affecting the national interest.