LS REVIEW
wealth and political power for the common good.
I. Constitutional Provisions:
A. State Policies
Section 9. The State shall promote a just and dynamic social order
that will ensure the prosperity and independence of the nation and
free the people from poverty through policies that provide
adequate social services, promote full employment, a rising
standard of living, and an improved quality of life for all.
Section 10. The State shall promote social justice in all phases of
national development.
Section 11. The State values the dignity of every human
person and guarantees full respect for human rights.
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Section 18. The State affirms labor as a primary social
economic force. It shall protect the rights of workers and
promote their welfare.
Section 19. The State shall develop a self-reliant and
independent national economy effectively controlled by
Filipinos.
Section 20. The State recognizes the indispensable role of the
private sector, encourages private enterprise, and provides
incentives to needed investments.
xxx
Section 8. The right of the people, including those employed in the
public and private sectors, to form unions, associations, or
societies for purposes not contrary to law shall not be
abridged.
B. SOCIAL JUSTICE AND HUMAN RIGHTS
Section 1. The Congress shall give highest priority to the
enactment of measures that protect and enhance the right of all
the people to human dignity, reduce social, economic, and political
inequalities, and remove cultural inequities by equitably diffusing
To this end, the State shall regulate the acquisition, ownership,
use, and disposition of property and its increments.
Section 2. The promotion of social justice shall include the
commitment to create economic opportunities based on freedom
of initiative and self-reliance.
C. LABOR
Section 3. The State shall afford full protection to labor, local and
overseas, organized and unorganized, and promote full
employment and equality of employment opportunities for all.
It shall guarantee the rights of all workers to self-organization,
collective bargaining and negotiations, and peaceful
concerted activities, including the right to strike in
accordance with law. They shall be entitled to security of
tenure, humane conditions of work, and a living wage. They
shall also participate in policy and decision-making processes
affecting their rights and benefits as may be provided by law.
The State shall promote the principle of shared responsibility
between workers and employers and the preferential use of
voluntary modes in settling disputes, including conciliation,
and shall enforce their mutual compliance therewith to foster
industrial peace.
The State shall regulate the relations between workers
and employers, recognizing the right of labor to its just share
in the fruits of production and the right of enterprises to
reasonable returns to investments, and to expansion and
growth.
Art. 151 (153) Regulation of industrial homeworkers
Employment of industrial homeworkers and field personnel shall be regulated by
the government through appropriate regulations to be issued by the Secretary of
Labor.
Art. 153 – Distribution of homework –
Employer – any person includes any person, natural or artificial, who for his
account or benefit or of any person residing outside the country directly or
indirectly or through any employee, agent contractor, subcontractor or any other
person:
a) Delivers, causes to be delivered, any goods, articles or materials to
be processed or fabricated in or about a home or thereafter to be
returned or to be disposed of or distributed in accordance with his
directions;
b) Sells any goods, articles or materials to be processed or fabricated in
or about a home and then rebuys them after such processing or
fabrication either himself or through some other person.
Department Order No. 5 , February 4, 1992 replaces Rule No. XIV of the
Implementing Rules of Book III.
Allows formation and registration of labor organizations of homeworkers;
Requires employers to pay and remit SSS, Medicare, and ECC premiums;
Claims of not more than P5,000.00 – RD; beyond – NLRC.
Apprentices:
Art. 57 – Statement of Objectives
The title aims to help meet the demand of the economy for trained manpower;
To establish a national apprenticeship program through participation of
employers, workers, government and non-government agencies; to establish
apprenticeship standards for the protection of apprentices.
Art. 58 – Definition of Terms
Apprenticeship – practical training on the job supplemented by theoretical
instruction.
Apprentice – a worker who is covered by a written apprenticeship agreement with
an individual employer or any of the recognized entities (in this Chapter).
Apprenticeable occupation – any trade, form of employment or occupation which
requires more than three (3) months of practical on the job training supplemented
by theoretical instruction;
Apprenticeship agreement – an employment contract wherein the employer binds
himself to train the apprentice and the apprentice accept the terms of the training.
Art. 59. Qualifications of apprentice:
a. At least fourteen (14) years of age;(superseded by RA 7610 as
amended by RA No. 7658 (Nov. 9 1993 which prohibits employment
of minors below 15 years of age.)
b. Possesses vocational aptitude and capacity for appropriate tests;
c. Possesses ability to comprehend and follow oral and written
instructions.
Art. 60. Employment of apprentices:
Only employers in highly technical industries my employ apprentices and
only in apprenticeable occupations approved by the Sec. Of Labor now by
TESDA. TESDA Act (RA 7796.
Requisites for employment of apprentices:
a. The employer must be engaged in a highly technical industry (a
trade, business, enterprise, industry
or other activity which utilizes the application of advanced technology
[Rule VI, Book II, Rules]);
b. The job must be an apprenticeable occupation (as determined by
TESDA).
Aptitude testing of applicants.
To ensure they have the minimum qualifications, applicants are required to take
aptitude tests; if employer has no capability/facility, the DOLE shall perform the
service free of charge.
Organization of apprenticeship programs, voluntary. EXCEPT:
a. when national security/ particular requirements for economic
development demand;
b. where services of foreign technicians are utilized by private
companies in apprenticeable trades, said companies are required to
set up appropriate apprenticeship programs.
Art. 71 – Deductibility of Training Costs. – ½ of the value of labor training
expenses incurred is deductible from taxable income. Provided that said
deduction does not exceed ten (10%) of the direct labor wage; and provided
further, that the employer pays his apprentices the minimum wage.
Art. 72 – Apprentices without compensation. - The Sec, DOLE may authorize the
hiring of apprentices without compensation when the training is required by the
school or training program curriculum, or as a requisite for graduation or board
examination.
Working scholar; liability of school – school liable for damages caused by
apprentices; scholars; trainees.
Contents of apprenticeship agreement:
a. Wage rates shall at least be 75% of applicable minimum wage;
b. Apprenticeable job;
c. Approved by the Sec. DOLE (Nitto vs. NLRC, et Al., G. R. No.
114337, Sept. 19, 1995.
Signing of apprenticeship agreement:
a. Must be signed by the employer or his representative;
b. If apprentice is a minor, must be signed on his behalf by his parents
or guardian, or by the DOLE.
Venue of apprenticeship programs:
 a) Conducted entirely by and within the sponsoring firm, establishment
or entity;
b) Within the DOLE training center;
c) Initial training in trade fundamentals in a training center or other
institutions with subsequent actual work participation within the
sponsoring firm, or entity during the final stages of the training.
Investigation of violations of agreement; appeal to the Sec. Of DOLE;Exhausting
administrative remedies.
LEARNERS: Persons hired as trainees in semi-skilled and other industrial
occupations which are not apprenticeable and which may be learned through
practical training on the job in a relatively short period not to exceed 3 months.
Art. 74 When Learners may by hired:
a. When no experienced workers are available;
b. The employment does ot create unfair competition in terms of labor
costs or impair or reduce labor standards.
Art. 75. – Learnership agreement:-
a. names and addresses of learners;
b. duration of the learnership period which shall not exceed 3 months;
c. wages of learners which shall start not lower than 75% of applicable
minimum wage;
d. a commitment to employ the learners if they so desire, as regular
employees upon completion of the training. (Learners who have
been suffered to work during the first 2 months shall be deemed
regular employees if the training is terminated by the employer
before the end of the stipulated period through no fault of the leaner.
e. The agreement shall be subject to inspection by the Sec. of the
DOLE.
Art. 76 – Learners employed in peace or incentive-rate jobs during the training
period shall be paid in full for the work done.
Art. 77. Penalty clause – violations shall be subject to the general penalty clause
in this CODE.
Handicapped workers (R.A. 7277)
Art. 78. – Handicapped workers are those whose earning capacity is impaired by
age, or physical or mental deficiency or injury
Art. 79 – Handicapped workers may be employed when their employment is
necessary to prevent curtailement of employment opportunities and it does not
create unfair competetition in labor costs or lower working standards.
Art. 80 – Employment agreement:
a. Names and addresses of handicapped workers
b. Rate to be paid which shall not be les thatn75% of minimum wage
applicable;
c. Duration of employment period
d. Work to be performed by the handicapped worker;
The agreement shall be subject to inspection by the DOLE.
Art. 81 – Eligibility for apprenticeship – They may be hired as apprentices or
learners if their handicap does not impede the performance of job operations
inthe particular occupations where they were hired.
Magna Carta for Disabled Persons - RA 7277 approved March 24, 1992 –
ensures equal opportunities for disabled persons and prohibits discrimination
against them.
_______________
 Wage distortion CBA vis-à-vis wage orders – CBA creditability
In organized establishments, wage increase given within 3 months prior
to the effectivity of a Wage Order shall be creditable, provided that a
provision on this is in the CBA; otherwise any increase granted by the
employer shall not be credited as compliance.
In unorganized establishements, wage increase granted by the employer
within five (5) months from effectivity of the Wage Order shall be credited
as compliance.
 Non-diminution of benefits- No Wage Order shall provide for wage rates
lower than the statutory minimum prescribed by Congress.
 Worker’s preference in case of bankruptcy
 Labor Code provisions for wage protection
 Allowable deductions without employee’s consent
 Attorney’s fees and union service fee in labor cases
 Criteria/factors for wage setting
 C. Rest day
 Right to weekly rest day
 Preference of the employee
 When work on rest day authorized
D. Holidays
1. Right to holiday pay
a) In case of absences
b) In case of temporary cessation of work
c) Of teachers, piece workers, seafarers, seasonal workers, etc.
2. Exclusions from coverage
Art. 124 – minimum wage- “floor wage”- employer not compelled to grant
increase across the board.
Two methods of minimum wage increase: a) fixing a determinate amount to add
to the prevailing minimum wage; b) the salary-ceiling method by which a
determinate amount is granted to employees receiving a certain denominated
salary ceiling.
Liability of contractor’s clients – construction, janitorial and security services, the
principal shall pay the increases in wage; if principal fails, the contractor and the
clients shall be jointly and sesverally liable.
Art. 125 – No wage order shall prevent workers from exercise of right to bargain;
Art. 126 – No injunction may be issued to stop proceedings before the Regional
Wage Boards;
Art. 127 – No wage orders granting lower than those prescribed by congress.
Art. 128 – Visitorial Powers-The Sec. Of Labor or his authorized representatives
– enforcement; not rested by Php 5,000. Limit to jurisdiction of RD;
SCOPE – R. A. 7730 repeals Arts. 129 and 217 (now 224 of the Labor Code).
Overturned rulings in Aboitiz and Servandos cases; Bombo Radyo – that the
existence of employer-employee relationship is a matter fraught with questions of
fact and law which is best resolved by the quasi-judicial body like the NLRC;
Jethro Intelligence & Security Corp and Yakult Phil. Vs. Hon. Sec. Of Labor, G.
R. No. 172537, Aug. 14, 2009 – recognizes the quasi-judicial power of the
Secretary of Labor and the Regional Director; they may issue writs of execution
and garnishment resulting from results of inspection.
Condition: that the employer-employee relationship still exists at the time the
complaint (formal or informal) is filed.
BUT – where the employer contests the findings of the labor standards and
welfare officers and raises issues which cannot be determined without
considering evidentiary matters, the RD must indorse the case to the Labor
Arbiter.
CBA Salary increase- charged against the 70% tuition increase (Centro Escolar
University Faculty Union vs. Hon. CA, G. R. No. 165486, May 31, 2006);
Art. 129 – Recovery of Wages, Simple Money Claims;
128 vs. 129 -
a) 128 inspection of establishments to compel compliance with labor
standards; while 129 refers to adjudication through summary
proceedings after notice and hearing;
b) Proceedings in 128 are offshoots of inspection, while in 129 – upon
complaint filed by interested party;
c) 128 involves employees still in the service while in 129 – may involve
past and present employees provided there is no demand for
reinstatement;
d) 128 does not fix maximum money claims while in 129 money claims
must not exceed Php 5K;
MONEY CLAIMS ONLY – (Urbanes case – RTC breach of contract)
SEnA – Single Entry Approach – Aggrieved may go to any DOLE office, get the
advice he needs, go through conciliation, etc.
NOTE: Publication, public hearings, mandatory. (Cagayan Sugar Milling
Co., vs. Sec. Of Labor, et al., G. R. No. 128399, 15 January 1988).
On 16 November 1993 Regional Wage Board passed Wage Order No. R02—02
providing increase in minimum wage in Region II. More than a year later, the
Board passed Wage Order R02-02-A amending Wage order No. R02-02 granting
instead for an across the board wage increase, retroactive to date of effectivity of
Wage Order 02-02.
Ruling: Wage Order 02-02A was struck down as a violation of Art. 123 of
the Labor Code.
4. CBA provision vis-à-vis overtime work
Interphil case – CBA provision – 8hrs. + 4 hrs overtime, valid.
Compressed Work Week (CWW) covered by DOLE Advisoroy No 02,
series of 2004. To be valid, conditions must be present:
1) The scheme is supported by majority of the employees
affected;
2) In firms using substances, oroperating in conditions that are
hazardous to health, a certification is needed from an
accredited safety organization or the firms’s safety
committee that work beyond eight hours is within the limits or
levels of exposure set by DOLE’s occupational safety and
health standards.
3) The DOLE regional office must be notified.
Validity of CWW Waiver upheld in Bisig ng Manggagawa sa Tryco, et al.,
vs NLRC, G. R. No. 151309, Oct. 15, 2008.
Flexible Work Assignments:
1) Reduction of workdays;
2) Rotation of workers;
3) Forced leave;
 4) Broken-time schedule;
5) Flexi-holiday schedule.
(See Art. 113 for reduction of work days which entails reduction or
deduction in pay.)
B. Wages:
Wage – means the remuneration or earnings, however designated;
capable of being expressed in terms of money, whether fixed or
ascertained on a time,
task, piece, or commission basis or other method of calculating the
same, which is payable by an employer to an employee under a written
or unwritten contract of employment for work done or to be done, or for
services rendered or to be rendered and includes the fair and reasonable
value, as determined by the Secretary of Labor, of board, lodging, or
other facilities customarily furnished by the employer to the employee.
“Fair and reasonable value” shall not include any profit to the employer
or to any person affiliated with the employer.
 “Wage” includes sales commissions. Songco vs. NLRC, G. R. No.
50999-501000, 23 March 1990. Zuelig terminated the services of
Songco on ground of retrenchment. Under the CBA between Zuelig
and the Union of which Songco was a member, he was entitled to a
retirement gratuity in an amount equivalent to one (1) month for
every year of service. The Labor Arbiter awarded him a separation
pay equivalent to his monthly salary (exclusive of commissions,
allowances, etc.) for every year of services;
Held: In the computation of the separation pay and back wages, the
transportation and emergency living allowances should be taken into
account.N. B. Commissions must be earned by actual market
transactions attributable to the employee, otherwise, no.
 Wage includes facilities and commodities. Facilities refer to the fair
and reasonable value of board, lodging and/or other facilities
customarily furnished by the employer to the employee, Ex. Food
and housing. He may deduct their value from the employees wages.
 Facilities vs. Supplements:
Facilities are items of expense necessary for the worker’s or his
family’s existence and subsistence hence they form part of the wage
and when furnished by the employer, they are deductible therefrom;
Supplements are extra remuneration or special privileges or benefits
given to or received by workers over and above their ordinary
earnings or wages.
 Requirements for deduction of value of facilities:
1) Proof that such facilities are customarily furnished by the trade;
2) The provision of deductible facilities must be accepted in writing
by the employee;
3) Facilities must be charged at fair and reasonable value.
(Mabeza vs. NLRC, G. R. No. 118506, 18 April 1997).
 Fair Day’s Wage for Fair Day’s Labor- “No work, no pay”
Where failure of a worker to work is not attributable to the employer,
the economic loss should not be shifted to the employer.
 Equal pay for equal work.
(International School Alliance of Educators (ISAE) vs, Quisumbing,
et al. G. R. No. 128845, 1 June 2000.)
 Coverage/exclusions
Farm tenancy or leasehold, farm workers, domestic service, home
workers (persons working in their respective homes in needle work
or in any cottage industry duly registered in accordance with law are
excluded from coverage.
 Wages vs. Salaries
Wages refers to the remuneration given to lowly workers usually
doing menial jobs; salaries to employees other than farm/agricultural
and ordinary labourer.
Art. 99 –Regional Minimum Wages – Amended by R. A. No. 6727 (Wage
Rationalization Act, approved 9 June 1989); Creation of Regional Tripartite
Wages and Productivity Boards.
Exemptions:
1) Household or domestic helpers, including family drivers and persons
in the personal service of another;
2) Homeworkers engaged in needlework and other handicrafts;
3) Workers employed in establishments registered with the NEDA that
they perform their work in their respective homes;
4) Workers in any duly registered cooperatives upon recommendation
of the Bureau of Cooperative Development upon approval of the
Secretary of the DOLE, to make it viable.
5) Barangay Micro Business Enterprises (RA No. 9178);
6) Retail business establishments employing not more than 10 (RA
6727
Art. 100 – Prohibition against elimination or diminution of benefits.;( practice that
has ripened into policy ).
1) Food and meal allowance;
2) Non-conributory retirement plan
3) Monthly ECOLA;
4) Full 13th month pay;
Exceptions:
1) Correction of error;
2) Negotiated benefits;
3) Wage order compliance;
4) Benefits on reimbursement basis;
 5) Recalissification of position;
6) Contingent benefits or conditional bonus;
7) Incentives for productivity.
Art. 101 – Payment by results . (Piece rate).
Night differentials; holiday pay;
1) Under supervision – entitled to night differential; holiday pay;
2) No supervision – not covered by the rules.
Basis for computation – average daily earnings during 7-day period
immediately preceding the regular holiday.
Entitlement ot 13th month pay:
Art. 102 – Forms of Payment –
Payment in checks or money order allowed if customary on date of the
effectivity of the code; special circumstances as specified in appropriate
regulations issued by the Secretary of Labor
Ar. 103 – Time of Payment –At least every two weeks or twice a month, intervals
not exceeding sixteen days.
For employees engage to perform a task which cannot be completed in two
weeks –
- Payments are made at intervals of not mre than 16 days in
proportion to the amount of work completed;
- Final settlement is made upon completion of the work.
Art. 104 – Place of Payment – must be paid at, or near the place of undertaken
except as otherwise provided by such regulations of the Secretary of Labor under
conditions to ensure greater protection of wages.
Exceptions:
- When it cannot be effected at or near the place of work for such
reasons as deterioration of peace and order conditions, or by reason
of impending emergencies like flood etc.
- When the employer provides free transportation to qne gqdk;
- Under analogous circumstances provide that the time spent for
getting their salaries are considered compensable;
- Prohibited: payment of wages in any bar, night club, or day club, etc.
Payment through banks – approved by at least 25% of employees; bank is
located within 1 km radius to a commercial bank’
Payment through ATM – allowed under Labor Advisory dated 25 November
1996.
Art. 105 – Direct Payment of Wages – Wages shall be paid directly to the
employee.
Exceptions:
1) In case of force majeure rendering direct payment impossible – but
with written authority given by the worker;
2) Where the worker has died – payment to the heirs without the
necessity of intestate proceedings. The claimants, if all of age, shall
execute an affidavit aattesting to their relationship to the deceased
and the fact that they are the heirs to the exclusion of all other
persons. If any of the heirs is a minor, the affidavit shall be executed
on his behalf by his natural guardian or next of kin. The affidavit shall
be presented to the employer who shall make payment through the
Secretary of Labor or his representative.
Art. 106 – Contractor or Subcontractor – Failure of the contractor or
subcontractor to pay the wages of the workers, the employer shall be jointly and
severally liable with his contractor or subcontractor to osuch employees to tohe
extent of the work performed under the contract in the same manner and extent
that he is liable to employees directly employed by him.
Art. 107 – Indirect Employer – Same as preceding article. This applies to any
person, partnership, association or corporation which, not being an empoyer
contracts with an independent contractor for the performance of any work, task,
job, or project.
Art. 108 – Posting of Bond – An employer or indirect employer may require the
subcontractor to put up a bond equal to the cost of labor to answer for the wages
due the employees should the contractor fail to pay the same.
Art. 109 – Solidary Liability – Trilateral relationship: 1) the principal; 2) the
contractor/
subcontractor; and 3) the workers.
 The cooperative as a contractor-employer?
 Memorandum Circular No 2012-12
Art. 110. – Workers’ preference in case of Bankruptcy – claims of workers, before
government and other creditors may be paid.
Art. 111 – Attorney’s fees – not more than 10% of the wages recovered. But
between client and lawyer, it could be quantum meruit.
 Non-lawyers not entitled to attorney’s fees;
 PAO lawyers not entited.
Art. 112 – Non-interference in disposal of wages –
Art. 113 – Wage Deduction -
Exceptions:
1) Where worker is insured with his consent and the deduction is to
recompense employer for premiums paid;
2) For union dues, where the right of union and workers to check off
has been recognized by the employer; with written consent of worker
(except non-union members who benefit from the provisions of the
CBA).;
 3) In cases where employer is authorized by law or regulations issued
by the DOLE Secretary.
Art. 114 – Deposits for loss or damage –prohibited, except in trades, occupations
or business where requiring deposits is a recognized practice or is necessary
and desirable as determined by the DOLE Secretary.
Art. 115 – Limitations – No deduction from deposits of an employee for the actual
amount of damage shall be done without first determining his responsibility for
the loss or damage.
Art. 116 – Withholding of wages and kickbacks prohibited.
Art. 117 – Deduction to ensure employment.
Art. 118 – Retaliatory measures –
Ar. 119 – False Reporting –
Art. 120 – Creation of Naitonal Wages and Productivity Commission-
Aart. 121 – Powers and Functions of the Commission – RA No. 6727 (Wage
Rationalization Act) – rationale for creation – “need for a group of “thinking men
and women” bound by statutory standards.
Art. 122 – Wage Order – RTWPB fixes minimum wage; appeal to NWPC.
NOTE: Publication, public hearings, mandatory. (Cagayan Sugar Milling
Co., vs. Sec. Of Labor, et al., G. R. No. 128399, 15 Jamuary 1988).
On 16 November 1993 Regional Wage Board passed Wage Order No.
R02—02 providing increase in minimum wage in Region II. More than a year
later, the Board passed Wage Order R02-02-A amending Wage order No. R002-
02 granting instead for an across the board wage increase, retroactive to date of
effectivity of Wage Order 02-02.
Ruling: Wage Order 02-02A was struck down as a violation of Art. 123 of
the Labor Code.
Art. 124 – Standard/Criteria for minimum wage fixing –
1) Demand for living wage;
2) Wage adjustment vis-a-vis consumer price index;
3) Cost of living and changes or increases thereon;
4) The needs of the workers and their families;
5) The need of industries to invest in the countryside;
6) Improvements in standards of living;
7) Prevailing wage levers;
8) Fair return of capital invested and capacity to pay of employers;
9) Effects on employment generation and family income; and,1`9ui
10) The equitable distribution and wearth along imperatives of economic
and social development.
Wage distortion – wage increase vs. CBA provisions. NOT STRIKEABLE.
Liability of contractors – the principal is liable; contract deemed amended as
regards wages.
Art. 125 – Freedom to Bargain –wage order cannot prevent employees from
bargaining for higher wages with their employer.
Art. 126 – Prohibition against injunction – no injunction may be issued y any court
or tribunal against proceedings before the Regional Boards;
Art. 127 – Non-Diminution of Benefits – No wage order shall provide for wages
lower than what had been fixed by Congress.
Art. 128 – Visitorial and Enforcement Power – visitorial power of the Secretary of
the DOLE;
Who determines existence of employer-employee relationship – still the labor
arbiter, not the Regional Director (People’s Broadcasting [Bombo Radyo Phil.,
Inc.] vs. The Sec. Of Labor, et al., G. R. No. 179652, 8 May 2009.) vs. Jethro
Intelligence and Security Corp., et al., vs. Hon. Sec. Of Labor, G. R. No. 172537,
14 August 2009 – the Regional Director has quasi-judicial powers.
Bombo Radyo revisited – Modified in an en banc decision of the Supreme Court
issued on 6 March 2012, [G. R. No. 179652]
 Wage distortionCBA vis-à-vis wage orders – CBA creditability
 Non-diminution of benefits
 Worker’s preference in case of bankruptcy
 Labor Code provisions for wage protection
 Allowable deductions without employee’s consent
 Attorney’s fees and union service fee in labor cases
 Criteria/factors for wage setting
Rest day
 Right to weekly rest day
 Preference of the employee
 When work on rest day authorized
________________
Martin Niemöller (1892–1984) was a prominent Protestant pastor who emerged
as an outspoken public foe of Adolf Hitler and spent the last seven years of Nazi
rule in concentration camps.
Niemöller is perhaps best remembered for the quotation:
First, they came for the Socialists, and I did not protest
Because I was not a Socialist.
Then they came for the Trade Unionists, and I did not protest
Because I was not a Trade Unionist.
Then they came for the Jews, and I did not protest
Because I was not a Jew.
Then they came for me—and there was no one left to speak for me.