ART 3 SEC.

1 OF THE CONSTITUTION
INTERNATIONAL SCHOOLS ALLIANCE OF EDUCATORS (ISAE) VS LEONARDO QUISUMBING ( in his
capacity as the Secretary of Labor and Employment; HON. CRESENCIANO B. TRAJANO in his capacity as the ActingSecretary
of Labor and Employment; DR. BRIAN MACCAULEY in his capacity as theSuperintendent of International School-
Manila; and INTERNATIONAL SCHOOL, INC.,respondents).
PONENTE: KAPUNAN

CASE LAW/ DOCTRINE:The principle of equal pay for equal value requires that persons who work
with substantially equal qualifications, skill,effort, and responsibility, under similar conditions, should
be paid similar salaries

FACTS:

In the case of International School Alliance of Educators (ISAE) vs. Hon. Leonardo A. Quisumbing, the
issue revolved around the disparity in salary rates between foreign-hire and local-hire faculty
members at the International School, Inc. The School classified its faculty into two categories:
foreign-hires and local-hires. Foreign-hires received certain benefits not accorded to local-hires,
including higher salaries, housing, transportation, shipping costs, taxes, and home leave travel
allowance. Foreign-hires are also paid a salary rate 25% more than local-hires. The School justified
this difference by citing two factors faced by foreign-hires: the “dislocation factor” and limited tenure.

When negotiations for a new CBA were held on June 1995, petitioner ISAE, a legitimate labor union
and the collective bargaining representative of all faculty members of the School, contested the
difference in salary rates between foreign and local-hires. This issue, as well as the question of
whether foreign-hires should be included in the appropriate bargaining unit, eventually caused a
deadlock between the parties. ISAE filed a notice of strike. Due to the failure to reach a
compromise in the National Conciliation and Mediation Board (NCMB), the matter reached the DOLE
which favored the School. Hence this petition

ISSUE(S): Whether the School unduly discriminated against the local-hires.

HELD: However, the Supreme Court ruled in favor of ISAE, emphasizing the principle of equal pay for
work of equal value. The Court held that employees should be given equal compensation regardless
of their nationality or point of hire classification. Discrimination based on economic allegiance or
domicile was deemed unconstitutional. Discrimination, particularly in terms of wages, is frowned
upon by the Labor Code. The Court also invoked international law principles to reinforce its stance
against discrimination.

While the court recognize the need of the school to attract foreign-hires, salaries should not be used
as an enticement to the prejudice of local-hires. There is no evidence that foreign-hires perform 25%
more efficiently or effectively than the local-hires. Both groups have similar functions and
responsibilities, which they perform under similar working conditions. The scheme is therefore unjust

THE CASE Exemplifies the constitutional commitment to equality and due process, ensuring that no
one is unfairly disadvantaged based on nationality or employment classification. The Constitution’s
mandate to promote social justice and protect workers’ rights.
BIRAOGO VS PHILIPPINES TRUTH COMMISSION
Ponente: Mendoza J

FACTS:

Two consolidated cases were brought before the Supreme Court of the Philippines.

G.R. No. 192935:

Petitioner: Louis “Barok” C. Biraogo, acting as a citizen and taxpayer.
Issue: Biraogo challenged the validity of Executive Order No. 1, issued on July 30, 2010, which
created the Philippine Truth Commission of 2010.
Argument: Biraogo contended that the executive order violated the legislative power of Congress
under Section 1, Article VI of the Constitution. He claimed that it usurped the constitutional authority
of the legislature to create a public office and allocate funds for it.
Court’s View: The Court acknowledged that while the Constitution and statutes do not explicitly
mention the president’s authority to conduct investigations or create bodies, this does not necessarily
mean that such authority is absent. The Court emphasized the role of the Constitution in establishing
and defining the fundamental powers of government.

G.R. No. 193036:

Petitioners: Edcel C. Lagman, Rodolfo B. Albano Jr., Simeon A. Datumanong, and Orlando B. Fua Sr.,
incumbent members of the House of Representatives.
Issue: These legislators also challenged the constitutionality of Executive Order No. 1.
Argument: They raised similar concerns about the president’s authority to create the Truth
Commission.
Court’s View: The Court reiterated that constitutional doctrines must remain steadfast, regardless of
changing circumstances. It emphasized the paramount role of the Constitution and the need to
determine conflicting claims of authority under it.

ISSUE/HELD:
1. Does Executive Order No. 1 violates the principle of separation of powers by usurping the powers
of Congress to create and to appropriate funds for public offices, agencies and commissions?

No, the establishment of the Truth Commission falls within the President's authority to
conduct investigations. However, the Court did not uphold the constitutionality of
Executive Order No. 1 because it appeared to violate the equal protection clause in the
Bill of Rights by singling out the "previous administration" as its sole focus.

Executive power is not limited to enforcing laws; it encompasses the President's role as the head of
state and head of government, with various powers, including foreign relations. Therefore, the
President's powers extend beyond the specific ones enumerated in the Constitution, and executive
power is more than the sum of those specific powers.The Executive branch has significant flexibility in
ensuring that laws are faithfully executed. One recognized power of the President, as
mandated by the Constitution, is the ability to create ad hoc committees. This power stems from
the need to gather facts and determine whether laws have been faithfully executed. The
creation of such committees has been upheld by the courts in cases like Department of Health v.
Camposano.

Regarding the allegation that Executive Order No. 1 infringes on Congress's power to
allocate funds for a public office, it should be clarified that there is no appropriation involved, only
allotment or allocation of already appropriated funds. Consequently, there is no encroachment
on Congress's authority to allocate funds. Moreover, the specific amount earmarked for the
commission need not be specified because the funds will come from the budget allocated to the
Office of the President by Congress. Furthermore, the allocation of funds for the Philippine Truth
Commission will be subject to existing auditing rules and regulations,ensuring the
appropriateness of the funding.
2. Does Executive Order No. 1 violate the equal protection clause? YES

Yes, it violates the equal protection clause in the Bill of Rights by singling out the "previous
administration" as its sole focus.

The equal protection clause applies to all official actions by the state, not just those of the
legislative branch. Its restrictions encompass all government departments, including the
political and executive branches, and extend to any state action that denies equal protection of the
laws, regardless of the agency or pretext used. The guarantee of equal protection of the laws does not
require absolute equality in the application of laws to all citizens of the state. The equal protection
clause allows for classification, which means grouping things together in theory or practice
because they share certain similarities.

However, for such classification to be considered valid, it must meet the test of reasonableness,
which consists of four requirements:
1) The classification rests on substantial distinctions;
2) It is germane to the purpose of the law;
3) It is not limited to existing conditions only; and
4) It applies equally to all members of the same class. "Superficial differences do not make for a valid
classification. Applying these principles to this case, Executive Order No. 1 should be
invalidated for violating the equal protection clause. The clear intent of the proposed
truth commission is to investigate and uncover the truth specifically related to "reported
cases of graft and corruption during the previous administration" alone. The intention to single out
the previous administration is evident, obvious, and undeniable.

CENTRAL BANK EMPLOYEES VS BANGKO SENTRAL

Ponente: Puno J

FACTS:

A legal dispute over the compensation and wage structure of the BSP employees. The Central Bank
Employees Association is the petitioner that represents the rank-and-file employees of the BSP, who
are covered by the Salary Standardization Law (SSL). The BSP and the Executive Secretary are the
respondents that defend the validity of Section 15 © of Republic Act No. 7653 ( THE NEW CENTRAL
BANK ACT), which provides that the compensation and wage structure of employees whose
positions fall under salary grade 19 and below shall be in accordance with the rates prescribed under
the SSL. The petitioner argues that this provision violates the equal protection clause of the
Constitution, as it creates an invidious distinction between the rank-and-file and the officers of the
BSP, who are exempted from the SSL and enjoy higher salaries and benefits.

ISSUE: Whether provision section 15 of RA 7653 is constitutional?

HELD: The Supreme Court, in its decision dated December 15, 2004, declared the last proviso of
Section 15 © of Republic Act No. 7653 unconstitutional, as it constitutes invidious discrimination on
the 2,994 rank-and-file employees of the BSP. The Court ruled that the proviso contravened the
principle of equity and the mandate of the Constitution to standardize the compensation of
government employees, including those in government-owned or controlled corporations with
original charters, such as the BSP.
Philippine Telegraph and Telephone Company vs. National Labor Relations Commission and Grace
de Guzman, G.R. No. 118978, May 23, 1997.
Ponente: REGALADO, J.:

FACTS: Grace de Guzman was hired by PT&T as a reliever and later as a probationary employee. She
indicated in her job application form and reliever agreements that she was single, although she had
married a few months earlier. PT&T had a policy of not accepting or retaining married women as
employees. When PT&T discovered her true civil status, it dismissed her for dishonesty and violation
of company policy. De Guzman filed a complaint for illegal dismissal and non-payment of cost-of-
living adjustment (COLA) before the NLRC.

ISSUE: Whether or not PT&T’s dismissal of de Guzman was valid and lawful.

HELD: No, PT&T’s dismissal of de Guzman was invalid and unlawful.

Rationale: The Supreme Court ruled that PT&T’s policy of not accepting or retaining married women
as employees was discriminatory and violated Article 136 of the Labor Code, which prohibits any
stipulation against marriage by an employer. The Court also held that PT&T’s policy contravened
Section 1, Article 3 of the Constitution, which guarantees the right of every person to due process
and equal protection of the laws. The Court further found that de Guzman’s concealment of her
marital status was not a valid ground for dismissal, as it was not a willful or malicious act, and it did
not affect her work performance or the company’s operations. The Court ordered PT&T to reinstate
de Guzman and pay her back wages and other benefits.

This case is significant because it affirms the right of women workers to be free from discrimination
based on their marital status, and to enjoy security of tenure and protection to labor as guaranteed
by the Constitution and the Labor Code. It also illustrates the principle that management
prerogatives are subject to legal limitations and must be exercised in good faith and with due regard
to the rights of the employees.