47 that it is prohibited for the workers to suspend their work abruptly, and after analysing the causes for justified dismissal established in Article 213, section a, of the Labour Code, it can be asserted that the termination of the employer-employee relationship may take place through justified dismissal in the case of the work stoppage. First, because it is an act of disobedience with respect to the order or instructions issued by the employer, and second because it means unjustified abandonment of the work or the reiterated reluctance to perform the work provided for in a contract, or the service to be provided. In labour matters and at the level of private enterprise, the Labour Code establishes clearly that the burden of proof of the facts that lead to the decision to dismiss corresponds to the employer, who is the person that adopts the measure. In the public domain, the State would have to determine which causes served as a basis to dismiss. n. Report of the expert Feliciano Olmedo Sanjur-Gordillo, attorney-at-law specialising in constitutional law an He is a University of Panama graduate in law and political science, with a Ph.D. law degree from the University of Salamanca, Spain. He was Justice of the First Section of the Supreme Court of the Republic of Panama, and as such he had to hear and decide on unconstitutionality proceedings. He was Attorney of the Administration and, while on this position, he had to take part in unconstitutionality proceedings. He was Secretary General of the Office of the Attorney General of the Nation, an entity of the Prosecutorial Agency that intervenes expressing opinions in unconstitutionality proceedings. For nearly 10 years he has devoted himself to his private law practice and during this time he has participated in unconstitutionality proceedings. In Panama, an unconstitutionality action, a consultation on unconstitutionality, or a warning of unconstitutionality may originate the unconstitutionality proceeding. In the first case it is necessary, together with the filing of the complaint, to present an authenticated copy of the public instrument that is contested. The complaint is forwarded to the Office of the Attorney General or of the Attorney of the Administration for its opinion, which must be issued within 10 days. After an opinion is delivered by one of the two offices, the matter must be “slated” in order for anyone having an interest in the proceedings to appear and deliver an opinion, or request that the action contested be declared either constitutional or unconstitutional. Then comes the decision of the Full Supreme Court, which is the entity responsible for deciding on the proceedings. The unconstitutionality remedy, which brought about the May 23, 1991 judgment, should have been processed according to the procedural steps described, as established in Book Four of the Judicial Code. It provides that in unconstitutionality actions, the Full Supreme Court shall limit itself to confronting the action contested with the constitutional rules deemed to have been violated. But, in addition, the Code grants the Full Supreme Court a much more dynamic role, since it demands of it that it confront the action contested with all such rules of the Constitution as, in its opinion, relate to the case and could eventually be found to have been violated by the action contested. It is not possible, within an unconstitutionality action, to seek reparation purposes against the author of the action, since there is not in Panama a legal rule that establishes that the unconstitutionality proceedings and the unconstitutionality action would have another purpose other than the preservation of the constitutional order. The legal effect that a declaration of unconstitutionality concerning a legal rule that serves as a basis for an administrative action has, is the disappearance of the rule from the legal system. The administration cannot revise such administrative actions for supervening illegality or unconstitutionality, because the effects of the judgment whereby a rule is declared unconstitutional are directed to the future;