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SECTION 5 1. Manosca vs. CA (G.R. NO.

106440, January 29, 1996) Facts: Petitioners inherited a piece of land when the parcel was ascertained by the NHI to have been the birth site of Felix Y. Manalo, the founder of Iglesia Ni Cristo, it passed Resolution No. 1, declaring the land to be a national historical landmark. Petitioners moved to dismiss the complaint on the main thesis that the intended expropriation was not for a public purpose and, incidentally, that the act would constitute an application of public funds, directly or indirectly, for the use, benefit, or support of Iglesia ni Cristo, a religious entity, contrary to the provision of Section 29(2), Article VI, of the 1987 Constitution. Issue: Whether or not the expropriation of the land whereat Manalo was born is valid and constitutional. Held: Yes. The taking to be valid must be for public use. There was a time when it was felt that a literal meaning should be attached to such a requirement. Whatever project is undertaken must be for the public to enjoy, as in the case of streets or parks. Otherwise, expropriation is not allowable. It is not so any more. As long as the purpose of the taking is public, then the power of eminent domain comes into play. As just noted, the constitution in at least two cases, to remove any doubt, determines what public use is. One is the expropriation of lands to be subdivided into small lots for resale at cost to individuals. The other is the transfer, through the exercise of this power, of utilities and other private enterprise to the government. It is accurate to state then that at present whatever may be beneficially employed for the general welfare satisfies the requirement of public use. 2.Graces vs Estenzo Facts: Two resolutions of the Barangay Council of Valencia, Ormoc Citywere passed:a. Resolution No. 5Reviving the traditional socio-religious celebration every fifth of April. This provided for the acquisition of the image of San Vicente Ferrer and the construction of a waiting shed. Funds for the said projects will be obtained through the selling of tickets and cash donations.b. Resolution No. 6- The chairman or hermano mayor of the fiesta would be the caretaker of the image of San Vicente Ferrer and that the image would remain in his residence for one year and until the election of his successor. The image would be made available to the Catholic Church during the celebration of the saints feast day.These resolutions have been ratified by 272 voters, and said projects were implemented. The image was temporarily placed in the altar of the Catholic Church of the barangay. However, after a mass, Father Sergio Marilao Osmea refused to return the image to the barangay council, as it was the churchs property since church funds were used in its acquisition.Resolution No. 10 was passed for the authorization of hiring a lawyer for the replevin case against the priest for the recovery of the image. Resolution No. 12 appointed Brgy. Captain Veloso as a representative to the case. The priest, in his answer assailed the constitutionality of the said resolutions. The priest with Andres Garces, a member of the Aglipayan Church, contends that Sec. 8 Article IV1 and Sec 18(2) Article VIII) 2 of the constitution was violated. Issue: Whether or Not any freedom of religion clause in the Constitution violated. Held: No. As said by the Court this case is a petty quarrel over the custody of the image. The image was

purchased in connection with the celebration of the barrio fiesta and not for the purpose of favoring any religion nor interfering with religious matters or beliefs of the barrio residents. Any activity intended to facilitate the worship of the patron saint(such as the acquisition) is not illegal. Practically, the image was placed in a laymans custody so that it could easily be made available to any family desiring to borrow the image in connection with prayers and novena. It was the councils funds that were used to buy the image, therefore it is their property. Right of the determination of custody is their right, and even if they decided to give it to the Church, there is no violation of the Constitution, since private funds were used. Not every government activity which involves the expenditure of public funds and which has some religious tint is violative of the constitutional provisions regarding separation of church and state, freedom of worship and banning the use of public money or property. 3. Pastor Dionisio Austria vs Respondents: NLRC 4 Division, CENTRAL PHILIPPINE UNION MISSION CORPORATION OF THE SEVENTH-DAYADVENTISTS, ELDER HECTOR V. GAYARES, PASTORS REUBEN MORALDE, OSCAR L. ALOLOR, WILLIAM U. DONATO,JOEL WALES, ELY SACAY, GIDEON BUHAT, ISACHAR GARSULA, ELISEO DOBLE, PORFIRIO BALACY, DAVID RODRIGO,LORETO MAYPA, MR. RUFO GASAPO, MR. EUFRONIO IBESATE, MRS. TESSIE BALACY, MR. ZOSIMO KARA-AN, and MR.ELEUTERIO LOBITANA, Facts:Private respondent Central Philippine Union Mission Corporation of the Seventh Day Adventists (SDA) is a religious corporationunder Philippine law and is represented by the other private respondents. Petitioner was a pastor of SDA until 1991, when hisservices were terminated.Austria worked with SDA for 28 years.He started as a literature evangelist in 1963 then got promoted several times. He became theAssistant Publishing Director in the West Visayan Mission of the SDA in 1968 and Pastor in the West Visayan Mission in 1972.Finally in 1989, he was promoted as District Pastor of the Negros Mission of the SDA.On various occasions from August to October 1991, Austria received several communications from Mr. Ibesate, treasurer of theNegros Mission, asking the former to admit accountability and responsibility for the church tithes and offerings collected by his wife,Thelma Austria, in his district and to remit the same to the Negros Mission.In his answer, petitioner said that he should not be made accountable since it was private respondent Pastor Buhat and Mr. Ibesatewho authorized his wife to collect the tithes and offerings since he was very sick to do the collecting at that time.Thereafter, petitioner went to the office of Pastor Buhat, president of the Negros Mission, and asked for a convention to settle thedispute between petitioner and Pastor Rodrigo. Pastor Buhat denied the request of petitioner because there was no quorum. The twoexchanged heated arguments until petitioner left the office. However, while on his way out, he heard Pastor Buhat saying, "Pastor daw inisog na ina iya (Pador you are talking tough) which prompted him to go back and overturn Pastor Buhats table, scatter booksin the office, bang Buhats attach case and throw the phone.Petitioner received a letter inviting him and his wife to attend the meeting to discuss the nonremittance of church collection and theevents that transpired between him and Pastor Buhat. A fact-finding committee was created to investigate petitioner. Subsequently,petitioner received a letter of dismissal citing misappropriation of denominational funds, willful breach of trust, serious misconduct,gross and habitual neglect of duties, and commission of an offense against the person of employer's duly authorized representative,as grounds for the termination of his services.(Nakakainis tong part na to dahil appeal nang appeal! Hahaha)1) Petitioner filed a complaint with the Labor Arbiter for illegal dismissal. = decision rendered in favor of petitioner 2) SDA appealed to NLRC = decision rendered in favor of respondent3)

Petitioner filed motion for reconsideration = reinstated decision of Labor Arbiter 4) SDA filed motion for reconsideration = decision rendered in favor of respondent (grabe ang kulit!)Hence, this recourse to the court by the petitioner. Issues:1) WON the Labor Arbiter/NLRC has jurisdiction to try and decide the complaint filed by petitioner against the SDA;2) WON the termination of the services of petitioner is an ecclesiastical affair, and, as such, involves the separation of church andstate; Held:1) YES.2) NO.Ratio Decidendi:The principle of separation of church and state finds no application in this case. The rationale of the principle of the separation of church and state is summed up in the familiar saying, "Strong fences make good-neighbors."The idea advocated by this principle isto delineate the boundaries between the two institutions and thus avoid encroachments by one against the other because of amisunderstanding of the limits of their respective exclusive jurisdictions.The case at bar does not concern an ecclesiastical or purely religious affair as to bar the State from taking cognizance of the same.An ecclesiastical affair is "one that concerns doctrine, creed, or form of worship of the church, or the adoption and enforcement withina religious association of needful laws and regulations for the government of the membership, and the power of excluding from suchassociations those deemed unworthy of membership. Examples of this so-called ecclesiastical affaits are proceedings for excommunication, ordinations of religious ministers, administration of sacraments and other activities with attached religioussignificance. The case at bar does not even remotely concern any of the given examples. What is involved here is the relationship of the church as an employer and the minister as an employee. It is purely secular and has no relation whatsoever with the practice of faith, worship or doctrines of the church. The matter of terminating an employee, which is purely secular in nature, is different fromthe ecclesiastical act of expelling a member from the religious congregation. 4.VICTORIANO VS. ELIZALDE UNION BENJAMIN VICTORIANO, plaintiff-appellee, vs. ELIZALDE ROPE WORKERS UNION and ELIZALDE ROPE FACTORY, INC., defendants, ELIZALDE ROPE WORKERS UNION, defendant-appellant. GRN L-25246 September 12, 1974 FACTS: Benjamin Victoriano (Appellee), a member of the religious sect known as the Iglesia ni Cristo, had been in the employ of the Elizalde Rope Factory, Inc. (Company) since 1958. He was a member of the Elizalde Rope Workers Union (Union) which had with the Company a CBA containing a closed shop provision which reads as follows: Membership in the Union shall be required as a condition of employment for all permanent employees workers covered by this Agreement. Under Sec 4(a), par 4, of RA 975, prior to its amendment by RA 3350, the employer was not precluded from making an agreement with a labor organization to require as a condition of employment membership therein, if such labor organization is the representative of the employees. On June 18, 1961, however, RA 3350 was enacted, introducing an amendment to par 4 subsectio n (a) of sec 4 of RA 875, as follows: xxx

but such agreement shall not cover members of any religious sects which prohibit affiliation of their members in any such labor organization. Being a member of a religious sect that prohibits the affiliation of its members with any labor organization, Appellee presented his resignation to appellant Union. The Union wrote a formal letter to the Company asking the latter to separate Appellee from the service because he was resigning from the Union as a member. The Company in turn notified Appellee and his counsel that unless the Appellee could achieve a satisfactory arrangement with the Union, the Company would be constrained to dismiss him from the service. Appellee filed an action for injunction to enjoin the Company and the Union from dismissing Appellee. The Union invoked the union security clause of the CBA and assailed the constitutionality of RA 3350 and contends it discriminatorily favors those religious sects which ban their members from joining labor unions. ISSUE: Whether Appellee has the freedom of choice in joining the union or not. RULING: YES. The Constitution and RA 875 recognize freedom of association. Sec 1 (6) of Art III of the Constitution of 1935, as well as Sec 7 of Art IV of the Constitution of 1973, provide that the right to form associations or societies for purposes not contrary to law shall not be abridged. Section 3 of RA 875 provides that employees shall have the right to self-organization and to form, join of assist labor organizations of their own choosing for the purpose of collective bargaining and to engage in concerted activities for the purpose of collective bargaining and other mutual aid or protection. What the Constitution and the Industrial Peace Act recognize and guarantee is the right to form or join associations. A right comprehends at least two broad notions, namely: first, liberty or freedom, i.e., the absence of legal restraint, whereby an employee may act for himself without being prevented by law; and second, power, whereby an employee may, as he pleases, join or refrain from joining an association. It is, therefore, the employee who should decide for himself whether he should join or not an association; and should he choose to join, he himself makes up his mind as to which association he would join; and even after he has joined, he still retains the liberty and the power to leave and cancel his membership with said organization at any time. The right to join a union includes the right to abstain from joining any union. The law does not enjoin an employee to sign up with any association. The right to refrain from joining labor organizations recognized by Section 3 of the Industrial Peace Act is, however, limited. The legal protection granted to such right to refrain from joining is withdrawn by operation of law, where a labor union and an employer have agreed on a closed shop, by virtue of which the employer may employ only members of the collective bargaining union, and the employees must continue to be members of the union for the duration of the contract in order to keep their jobs. By virtue of a closed shop agreement, before the enactment of RA 3350, if any person, regardless of his religious beliefs, wishes to be employed or to keep his employment he must become a member of the collective bargaining union. Hence, the right of said employee not to join the labor union is curtailed and withdrawn.

To that all-embracing coverage of the closed shop arrangement, RA No.3350 introduced an exception, when it added to Section 4 (a) (4) of the Industrial Peace Act the following proviso: but such agreement shall not cover members of any religious sects which prohibit affiliation of their members in any such labor organization. Republic Act No. 3350 merely excludes ipso jure from th e application and coverage of the closed shop agreement the employees belonging to any religious sects which prohibit affiliation of their members with any labor organization. What the exception provides is that members of said religious sects cannot be compelled or coerced to join labor unions even when said unions have closed shop agreements with the employers; that in spite of any closed shop agreement, members of said religious sects cannot be refused employment or dismissed from their jobs on the sole ground that they are not members of the collective bargaining union. It does not prohibit the members of said religious sects from affiliating with labor unions. It still leaves to said members the liberty and the power to affiliate, or not to affiliate, with labor unions. If, notwithstanding their religious beliefs, the members of said religious wets prefer to sign up with the labor union, they can do so. If in deference and fealty to their religious faith, they refuse to sign up, they can do so; the law does not coerce them to join; neither does the law prohibit them from joining, and neither may the employer or labor union compel them to join. The Company was partly absolved by law from the contractual obligation it had with the Union of employing only Union members in permanent positions. It cannot be denied, therefore, that there was indeed an impairment of said union security clause. The prohibition to impair the obligation of contracts is not absolute and unqualified. The prohibition is general. The prohibition is not to be read with literal exactness, for it prohibits unreasonable impairment only. In spite of the constitutional prohibition, the State continues to possess authority to safeguard the vital interests of its people. Legislation appropriate to safeguarding said interests may modify or abrogate contracts already in effect. For not only are existing laws read into contracts in order to fix the obligations as between the parties, but the reservation of essential attributes of sovereign power is also read into contracts as a postulate of the legal order. The contract clause of the Constitution. must be not only in harmony with, but also in subordination to, in appropriate instances, the reserved power of the state to safeguard the vital interests of the people. This has special application to contracts regulating relations between capital and labor which are not merely contractual, and said labor contracts, for being impressed with public interest, must yield to the common good. The purpose to be achieved by RA 3350 is to insure freedom of belief and religion, and to promote the general welfare by preventing discrimination against those members of religious sects which prohibit their members from joining labor unions, confirming thereby their natural, statutory and constitutional right to work, the fruits of which work are usually the only means whereby they can maintain their own life and the life of their dependents. The individual employee, at various times in his working life, is confronted by two aggregates of power collective labor, directed by a union, and collective capital, directed by management. The union, an institution developed to organize labor into a collective force and thus protect the individual employee from the power of collective capital, is, paradoxically, both the champion of employee rights, and a new source of their frustration. Moreover, when the Union interacts with management, it produces yet a third

aggregate of group strength from which the individual also needs protection the collective bargaining relationship. The free exercise of religious profession or belief is superior to contract rights. In case of conflict, the latter must yield to the former. The purpose of RA 3350 is to serve the secular purpose of advancing the constitutional right to the free exercise of religion, by averting that certain persons be refused work, or be dismissed from work, or be dispossessed of their right to work and of being impeded to pursue a modest means of livelihood, by reason of union security agreements. To help its citizens to find gainful employment whereby they can make a living to support themselves and their families is a valid objective of the state. The Constitution even mandated that the State shall afford protection to labor, promote full employment and equality in employment, ensure equal work opportunities regardless of sex, race or creed and regulate the relation between workers and employers. The primary effects of the exemption from closed shop agreements in favor of members of religious sects that prohibit their members from affiliating with a labor organization, is the protection of said employees against the aggregate force of the collective bargaining agreement, and relieving certain citizens of a burden on their religious beliefs; and by eliminating to a certain extent economic insecurity due to unemployment, which is a serious menace to the health, morals, and welfare of the people of the State, the Act also promotes the well-being of society. It is our view that the exemption from the effects of closed shop agreement does not directly advance, or diminish, the interests of any particular religion. Although the exemption may benefit those who are members of religious sects that prohibit their members from joining labor unions, the benefit upon the religious sects is merely incidental and indirect. The purpose of RA 3350 was not to grant rights to labor unions. The rights of labor unions are amply provided for in Republic Act No. 875 and the new Labor Code. The Act does not require as a qualification, or condition, for joining any lawful association membership in any particular religion or in any religious sect; neither does the Act require affiliation with a religious sect that prohibits its members from joining a labor union as a condition or qualification for withdrawing from a labor union. Joining or withdrawing from a labor union requires a positive act Republic Act No. 3350 only exempts members with such religious affiliation from the coverage of closed shop agreements. So, under this Act, a religious objector is not required to do a positive act-to exercise the right to join or to resign from the union. He is exempted ipso jure without need of any positive act on his part. WHEREFORE, the instant appeal is dismissed. from Atty. Daan^^

SECTION6 1.Salonga vs Hermoso -Salonga filed a mandamus proceeding to compel Hermoso of the Travel Processing Center to issue a certificate of eligibility to travel to Salonga. This is not however the first time that Salonga filed such a complaint and this issue is considered moot and academic. The Soc-Gen, in his reply, has already indicated that the certificate was indeed issued and that there should be no cause of action. The issuance of the certificate is in pursuant to the Universal Declaration of Human Rights on the Right to Travel. The Philippines, even though it is under martial law, shall in no instance facilitate the erosion of human rights. The Travel Processing Center should exercise the utmost care to avoid the impression that certain citizens desirous of exercising their constitutional right to travel could be subjected to inconvenience or annoyance this is to avoid such similar cases to face the Court which needlessly expire the Courts effort and time. Salonga vs Hermosoby on Nov 24, 2011Political Law Right to Travel Even During Martial Law Salonga filed a mandamus proceeding to compel Hermoso of the Travel Processing Center to issue a certificate of eligibility to travel to Salonga. This is not however the first time that... 2. YAP vs. Court of Appeals Ramon Yap purchased a parcel of land situated in Quezon City, from the spouses Carlos and Josefina Nery. The lot was thereupon registered in the name of Ramon Yap he also declared the property in his name for tax purposes and paid the real estate taxes due threon from 1966 to 1992. In 1962 Ramon Yap constructed a two storey 3 door apartment building for the use of the Yap family. 1/5 of the cost of the construction was defrayed by Ramon Yap while the rest was shouldered by Chua Mia, the mother of Lorenzo, Benjamin and Ramon. Upon the request of the old woman the tax declaration for real estate was placed under the name of Lorenzo Yap. Lorenzo Yap died on 11 July 1970. A few month leter, his heirs including Ramon yap allowed petitioners to use one unit of the apartment building. On March 18, 1992, Ramon Yap sold the land and his share of the 3door apartment to his brother, his herein co-respondent Benjamin Yap, for the sum of P337,500.00 pursuant to a Deed of Sale. Petitioners advised respondents of the formers claim of ownership over the property and demanded that respondents execute the proper deed necessary to transfer the title to them. Petitioners claim that Lorenzo requested his brother Ramon to allow the use of the latters name in the purchase, registration, and declaration for tax purposes of the subject lot to which Ramon Yap consented. It was agreed that the property would remain registered in the name of Ramon yap until such time as Lorenzo would have acquired Philippine citizenship but that, should Lorenzo, the lot would then be transferred to Lorenzos heirs upon the latters naturalization. Both the Trial Court and the Appellate Court denied the petition and dismisses the case. Issue: WON the petitioners are entitled to own the questioned property.

HELD: Petitioners were not able to prove adequately the agreement between them and the respondent. The petition was denied and affirmed the decision of the court of appeals. 3.FERDINAND E. MARCOS vs. HON. RAUL MANGLAPUS (177 SCRA 668) Case Digest Facts:After Ferdinand Marcos was deposed from the presidency, he and his family fled to Hawaii. Now in his deathbed, petitioners are asking the court to order the respondents to issue their travel documents and enjoin the implementation of the Presidents decision to bar their return to the Philippines. Petitioners contend under the provision of the Bill of Rights that the President is without power to impair their liberty of abode because only a court may do so within the limits prescribed by law. Nor, according to the petitioners, may the President impair their right to travel because no law has authorized her to do so. Issue:Does the president have the power to bar the Marcoses from returning to the Philippines?

Ruling:The President has the obligation, under the Constitution to protect the people, promote their welfare and advance national interest.

This case calls for the exercise of the Presidents power as protector of the peace. The president is not only clothed with extraordinary powers in times of emergency, but is also tasked with day-to-day problems of maintaining peace and order and ensuring domestic tranquility in times when no foreign foe appears on the horizon. The documented history of the efforts of the Marcoses and their followers to destabilize the country bolsters the conclusion that their return at this time would only exacerbate and intensify the violence directed against the state and instigate more chaos. The State, acting through the Government, is not precluded from taking preemptive actions against threats to its existence if, though still nascent they are perceived as apt to become serious and direct protection of the people is the essence of the duty of the government. The Supreme Court held that the President did not act arbitrarily or with grave abuse of discretion in determining the return of the petitioners at the present time and under present circumstances poses a serious threat to national interest and welfare prohibiting their return to the Philippines. The petition is DISMISSED. 4.Manotoc vs CA Facts: Petitioner was charged with estafa. He posted bail. Petitioner filed before each of the trial courts a motion entitled, "motion for permission to leave the country," stating as ground therefor his desire to go to the United States, "relative to his business transactions andopportunities." The prosecution opposed said motion and after duehearing, both trial judges denied the same. Petitioner thus filed apetition for certiorari and mandamus before the then Court of Appealsseeking to annul the orders dated March 9 and 26, 1982, of Judges Camilon and Pronove, respectively, as well as the communication-request of

the Securities and Exchange Commission, denying his leave to travel abroad. He likewise prayed for the issuance of the appropriate writ commanding the Immigration Commissioner and the Chief of the Aviation Security Command (AVSECOM) to clear him for departure. The Court of Appeals denied the petition. Petitioner contends that having been admitted to bail as a matter of right, neither the courts which granted him bail nor the Securities and Exchange Commission which has no jurisdiction over his liberty could prevent him from exercising his constitutional right to travel.

Issue: Whether or Not his constitutional right to travel has been violated.

Held: A court has the power to prohibit a person admitted to bail from leaving the Philippines. This is a necessary consequence of the nature and function of a bail bond. The condition imposed upon petitioner to make himself available at all times whenever the court requires his presence operates as a valid restriction on his right to travel. Indeed, if the accused were allowed to leave the Philippines without sufficient reason, he may be placed beyond the reach of the courts. Petitioner has not shown the necessity for his travel abroad. There is no indication that the business transactions cannot be undertaken by any other person in his behalf.

5.Kant Kwong vs PCGG The right to travel, along with the right to freedom of movement, are constitutionallyguaranteed rights. The petitioners had been barred by the government from leaving thecountry. This was done through a HoldOrder. The petitioners argued that this was violative of their right to travel. The Court held that the HoldOrders impaired the petitioners'constitutional right to travel. The Hold-Orders had already expired and the grounds for theirissuance had become moot. The Court said, "The right to travel and to freedom of movement isa fundamental right guaranteed by the 1987 Constitution and the Universal Declaration of Human Rights to which the Philippines is a signatory. That right extends to all residentsregardless of nationality. And everyone has the right to an effective remedy by the competentnational tribunals for acts violating the fundamental rights granted him by the Constitution orby law. While such right is not absolute but must yield to the State's inherent police powerupon which the Hold-Orders were premised, no 'good reasons' have been advanced whichcould justify the continued enforcement of the Hold-Orders." Thus, the Court held that thegovernment had abused its discretion in maintaining the Hold-Orders for an indefinite length of time, as to do so arbitrarily violated the petitioners' fundamental right to freedom of movement. It cited the UDHR in so doing

6. PASEI vs DRILON 163 SCRA 380

Facts:Petitioner, Phil association of Service Exporters, Inc., is engaged principally in the recruitment of Filipino workers, male and female of overseas employment. It challenges the constitutional validity of Dept. Order No. 1 (1998) of DOLE entitled Guidelines Governing the Temporary Suspension of Deployment of Filipino Domestic and Household Workers. It claims that such order is a discrimination against males and females. The Order does not apply to all Filipino workers but only to domestic helpers and females with similar skills, and that it is in violation of the right to travel, it also being an invalid exercise of the lawmaking power. Further, PASEI invokes Sec 3 of Art 13 of the Constitution, providing for worker participation in policy and decision-making processes affecting their rights and benefits as may be provided by law. Thereafter the Solicitor General on behalf of DOLE submitting to the validity of the challenged guidelines involving the police power of the State and informed the court that the respondent have lifted the deployment ban in some states where there exists bilateral agreement with the Philippines and existing mechanism providing for sufficient safeguards to ensure the welfare and protection of the Filipino workers. Issue:Whether or not there has been a valid classification in the challenged Department Order No. 1. Decision:SC in dismissing the petition ruled that there has been valid classification, the Filipino female domestics working abroad were in a class by themselves, because of the special risk to which their class was exposed. There is no question that Order No.1 applies only to female contract workers but it does not thereby make an undue discrimination between sexes. It is well settled hat equality before the law under the constitution does not import a perfect identity of rights among all men and women. It admits of classification, provided that: 1. Such classification rests on substantial distinctions 2. That they are germane to the purpose of the law 3. They are not confined to existing conditions 4. They apply equally to al members of the same class In the case at bar, the classifications made, rest on substantial distinctions. Dept. Order No. 1 does not impair the right to travel. The consequence of the deployment ban has on the right to travel does not impair the right, as the right to travel is subjects among other things, to the requirements of public safety as may be provided by law. Deployment ban of female domestic helper is a valid exercise of police power. Police power as been defined as the state authority to enact legislation that may interfere with personal liberty or property in order to promote general welfare. Neither is there merit in the contention that Department Order No. 1 constitutes an invalid exercise of legislative power as the labor code vest the DOLE with rule making powers.