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Laguna Lake Development Authority vs CA (R No. 120865-71, Dec.

7 1995)

FACTS:
The Laguna Lake Development Authority (LLDA) was created through Republic Act No. 4850. It was granted,
inter alia, exclusive jurisdiction to issue permits for the use of all surface water for any project or activity in or
affecting the said region including navigation, construction, and operation of fishpens, fish enclosures, fish
corrals and the like.

Then came RA 7160, the Local Government Code of 1991. The municipalities in the Laguna Lake region
interpreted its provisions to mean that the newly passed law gave municipal governments the exclusive
jurisdiction to issue fishing privileges within their municipal waters.

ISSUE:
WON the LLD has jurisdiction over the Laguna Lake and its environs insofar as the issuance of permits for
fishing privileges is concerned, the LLDA or the towns and municipalities comprising the region.

HELD:
Yes, LLDA has jurisdiction over such matters because the charter of the LLDA prevails over the Local
Government Code of 1991. The said charter constitutes a special law, while the latter is a general law. It is basic
in statutory construction that the enactment of a later legislation which is a general law, cannot be construed to
have repealed a special law. The special law is to be taken as an exception to the general law in the absence of
special circumstances forcing a contrary conclusion.

In addition, the charter of the LLDA embodies a valid exercise of police power for the purpose of protecting
and developing the Laguna Lake region, as opposed to the Local Government Code, which grants powers to
municipalities to issue fishing permits for revenue purposes.

Thus it has to be concluded that the charter of the LLDA should prevail over the Local Government Code of
1991 on matters affecting Laguna de Bay.
People vs Domiciano Baylon (G.R. No. L-35785, May 29, 1974)

Facts: Susan Aspili, a minor at the time of the alleged crime used to commute to go to school, about 4km away
from her barrio. At about 5am oon her way to school, she was nearing the barrio school of Colo. The appellant,
Domiciano Baylon emerged and embraced her, pulled towards him and dragged her in the direction of the
canal. Susana, on the other hand, tried all her best to resist but was then hit by Domiciano on her abdomen,
resulting in her weakened condition. After the wicked act happened, Susana ran back to her home still suffering
from pain in her private part, shoulders and thighs. She ran towards her mother and confessed what had
happened. Her parents took action and asked for help from their barrio captain. Judge Jose Madarang wrote a
well-written decision to convict the accused, Domiciano, for the crime of rape. A careful study of the record
fails to prove his alibi that he was not guilty of the said accusation.

Issue: WON the appellant’s defense of alibi will be given credence than those of the offended party’s statement.

Held: No, the appellant’s defense of alibi will not be given credence considering that there is an absence of
novelty reflected on his alibi.

The State, as parens patriae, is under the obligation to minimize the risk of harm to those, who, because of
minority, are as yet unable to take care of themselves falls.

In this case, wherein complainant was a minor, the Court has given marked receptivity on its part to lend
credence to her version of what transpired. Appellant failed to establish his defense. The Court had correctly
observed that no women, especially a minor, would willingly expose herself to public trial embarrassment.
Considering further that Susana’s testimony is firm, categorical and straightforward. Hence, the Court ruled in
favor of the offended party.
TSPIC Corporation vs. TSPIC Employees Union (G.R. No, 163419, February 13, 2008)

Facts: The TSPIC Corporation and the Corporation Union entered into a Collective Bargaining Agreement
which provides an increase of salary for the latter’s members for the year 2000-2002 starting from January
2000 and was materialized on the same year. However, later that year, the Regional Tripartite Wage and
Production Board raised daily minimum wage from 223.50 pesos to 250 pesos starting from November 1, 2000.
On the last quarter of 2000, 17 employees attained regular employment and received 25% to 10% increase in
salary. The following year, TSPIC implemented new wage rates as mandated by the CBA. As a result, 9
employees who were senior to the group of 17 regulized employees, received less wages. A few week after the
salary increase for the year 2001, TSPIC Human Rights Department informed the 24 employees that due to
error in the automated payroll system, they were overpaid and the overpayment would be deducted from their
salaries in a staggered basis. The Union, on the other hand, asserted that there was no error and the deduction of
the alleged overpayment from employees constituted diminution of pay.

Issue: WON the alleged overpayment constitutes diminution of pay by the TSPIC.

Held: Yes, the alleged overpayment constitutes diminution of pay.

Under Sec. 18, Article 18 of the 1987 Constitution, it states that:

“The State affirms labor as a primary social economic force. It shall protect the rights of workers and promote
their welfare.”

In this case, CBA entered into by unions and their employees are binding upon the parties and be acted in strict
compliance therewith. The Court finds that there was no overpayment when there was an increase of salary for
the members of the Union simultaneous with the increasing of minimum wage for workers in the NCR. The
CBA should be followed and the 9 senior employees promoted as regular employees shall be entitled for the
increase in their salaries, the same as with lower rank workers.

PAWU vs NLRC (G.R. No. L-50320, July 31, 1981)


Facts:

Negotiations were held between petitioner and respondent due to the complaints by the petitioner with the
Department of Labor. Both parties concluded and signed a Collective Bargaining Agreement that provided 3-
stage wage increase of 0.80 cents daily for all rank and file employees. Meanwhile, P.D. 1123 was enacted to
take effect providing for an increase by 60 pesos in the living allowance ordained by P.D. 525.

The controversy arose when petitioner contends that allowance under P.D. 1123 is distinct and separate from
the negotiated wage increase of 0.80 cents daily on the grounds that respondent violated the CBA and
committed unfair labor practice when it refused to pay the new wage increase of 0.80 cents daily to the
employees within the bargaining unit.

On the contrary, respondents assails this contention and maintains that there was no violation of the CBA and
that its application of the new wage increase as partial compliance with P.D. 1123 is well within the provisions
of the latter.

Issue: WON the respondent’s enactment of 60 pesos in the living allowance is a violation to the CBA

Held: Yes, respondent’s enactment of an increase of 60 pesos in the living allowance is a violation to the CBA.

At the time CBA was perfected, P.D. 1123 was already in force and effect. The refusal to implement the NWI
for the first year of the CBA makes the respondent guilty of unfair labor practice on the grounds that the
respondent company acted in bad faith.

In this case, upon signing the CBA, respondent company did not let the petitioner be informed that it was going
to apply part of the allowances being paid under P.D. 1123 to the wage increase provided in the CBA.
Moreover, the Court rule that respondent company must perforce pay both the benefits under P.D.1123 and the
CBA. In case of doubt, all legislation and labor contracts shall be construed in favor of the safety and decent
living for the laborer.

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