G.R. No. 167614 [37] [38] [39] [40] [41] [42] [43] [44] [45] [46] [47] [48] [49] [50] [51] [52] [53] [54] [55] [56] [57] [58] [59] [60] [61] [62] [63] [64] [65] [66] [67] [68] [69] [70] 30 of 33 http://sc.judiciary.gov.ph/jurisprudence/2009/march2009/167614.htm Memorandum of the Solicitor General, rollo, p. 680. Memorandum for Petitioner, id. at 755. Id. at 761-763. Rollo, pp. 645-646 and 512-513. Alfredo L. Benipayo was Solicitor General at the time the Comment was filed. Antonio Eduardo B. Nachura (now an Associate Justice of the Supreme Court) was Solicitor General when the Memorandum was filed. Memorandum of the Solicitor General, id. at 662-665. G.R. No. 113658, March 31, 1995, 243 SCRA 190. G.R. No. 110524, July 29, 2002, 385 SCRA 306. Memorandum of the Solicitor General, rollo, pp. 668-678. Id. at 682. The Province of North Cotabato v. The Government of the Republic of the Philippines Peace Panel on Ancestral Domain, G.R. No. 183591 October 14, 2008. Automotive Industry Workers Alliance v. Romulo, G.R. No. 157509, January 18, 2005, 449 SCRA 1. David v. Macapagal-Arroyo, G.R. No. 171396, May 3, 2006, 489 SCRA 160. Arceta v. Mangrobang, G.R. No. 152895, June 15, 2004, 432 SCRA 136. Moldex Realty, Inc. v. Housing and Land Use Regulatory Board, G.R. No. 149719, June 21, 2007, 525 SCRA 198; Marasigan v. Marasigan, G.R. No. 156078, March 14, 2008, 548 SCRA 409. Matibag v. Benipayo, G.R. No. 149036, April 2, 2002, 380 SCRA 49. Rollo, p. 145. Id. at 166. Smart Communications, Inc. v. National Telecommunications Commission, G.R. No. 151908, August 12, 2003, 408 SCRA 678. Equi-Asia Placement, Inc. v. Department of Foreign Affairs, G.R. No. 152214, September 19, 2006, 502 SCRA 295. Memorandum for Petitioner, rollo, pp. 741-742. Ortigas & Co., Ltd. v. Court of Appeals, G.R. No. 126102, December 4, 2000, 346 SCRA 748. Picop Resources, Inc. v. Base Metals Mineral Resources Corporation, G.R. No. 163509, December 6, 2006, 510 SCRA 400. Walker v. Whitehead, 83 U.S. 314 (1873); Wood v. Lovett, 313 U.S. 362, 370 (1941); Intrata-Assurance Corporation v. Republic of the Philippines, G.R. No. 156571, July 9, 2008; Smart Communications, Inc. v. City of Davao, G.R. No. 155491, September 16, 2008. Executive Secretary v. Court of Appeals, G.R. No. 131719, May 25, 2004, 429 SCRA 81, citing JMM Promotion and Management, Inc. v. Court of Appeals, G.R. No. 120095, August 5, 1996, 260 SCRA 319. Ortigas & Co., Ltd. v. Court of Appeals, supra note 58. Section 18. The State affirms labor as a primary social economic force. It shall protect the rights of workers and promote their welfare. 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. See City of Manila v. Laguio, G.R. No. 118127, April 12, 2005, 455 SCRA 308; Pimentel III v. Commission on Elections, G.R. No. 178413, March 13, 2008, 548 SCRA 169. League of Cities of the Philippines v. Commission on Elections G.R. No. 176951, November 18, 2008; Beltran v. Secretary of Health, G.R. No. 139147,November 25, 2005, 476 SCRA 168. Association of Small Landowners in the Philippines v. Secretary of Agrarian Reform, G.R. No. 78742, July 14, 1989, 175 SCRA 343. Los Angeles v. Almeda Books, Inc., 535 U.S. 425 (2002); Craig v. Boren, 429 US 190 (1976). There is also the "heightened scrutiny" standard of review which is less demanding than "strict scrutiny" but more demanding than the standard rational relation test. Heightened scrutiny has generally been applied to cases that involve discriminatory classifications based on sex or illegitimacy, such as in Plyler v. Doe, 457 U.S. 202, where a heightened scrutiny standard was used to invalidate a State's denial to the children of illegal aliens of the free public education that it made available to other residents. America v. Dale, 530 U.S. 640 (2000); Parents Involved in Community Schools v. Seattle School District No. 1, 551 U.S. (2007); http://www.supremecourtus.gov/opinions/06pdf/05-908.pdf. 1/26/2016 3:06 PM