48 therefore, for as long as the legal rule is in force, it serves as a legal basis for the action performed during its term of validity. If, parallel to the administrative conflicts proceeding, an unconstitutionality action is brought where a legal rule that must be applicable in the administrative proceeding is questioned and, before a decision is made in the administrative conflicts proceeding the Full Court solves the unconstitutionality case and declares the rule unconstitutional, the Justices of the Third Section of the Supreme Court have to take such decision into consideration, since otherwise a legal rule that no longer exists would be applied. As recognised by the general doctrine, the administration has broad powers to annul its actions automatically, with some exceptions. In Panama, the protection of legality corresponds to the Third Section of the Supreme Court. With respect to contestation, once the governmental recourse is exhausted, the case is forwarded to the Third Section of the Supreme Court. The Constitution establishes that if the Third Section deems the action, of dismissal in this case, legitimate, the judgment is final, definitive and binding, and that it has to be published in the Official Gazette. Thus, it would be very difficult for the administration, in this second assumption, to revise such action as to constitutionality or legality, because of the fact that a decision that legally resolved the case exists. This is independent from the possibility of the administration itself to revise the situation as a matter of course, which it could do based on its discretional powers to revise. Chapter Three of the Panamanian Constitution regulates individual and social rights and duties; it includes a chapter that contains the basis for the regulation of the relationship between capital and labour. The basic rules and principles that govern the management of State personnel appear in Chapter Eleven, conceived under the public servant title. The Constitution defines what public servants are at the beginning of this Chapter, and it establishes separate legal systems for relations between capital and labour, and relations between public servants and the State. In Chapter Two the Constitution establishes public careers, among which it mentions the administrative career, the educational career, the health career, and all others deemed necessary according to the legislators, and it establishes in Article 300 that these careers shall be established and regulated by law. Article 294 establishes that any official, any person holding a public position, who receives remuneration from the State, is a public servant. Article 2 of the Labour Code adopted in 1971, established that as a general rule it was not applicable to public servants, save for the rules that the Code itself would establish exceptionally and for a specific purpose. There were some cases of public servants who were governed in certain aspects by a system similar to that of labour law, as in the case of Law 8 of 1975 and certain laws of 1979 on some port workers. Article 295 of the Constitution of Panama establishes that public servants shall be of Panamanian nationality without distinction of race, sex. religion, beliefs or political membership, and that their appointment and dismissal shall not be the absolute and discretional power of any one authority, except as regards the merits system and stability on the job for public servants, which shall depend on proficiency, loyalty and morality in the service. When the current administrative career law indicates the rights and duties of public servants it does not point out in a general manner the right to the stability of public servants. However, when it mentions the rights of administrative career officials it grants the right to stability. In jurisprudence that it has been issuing for several decades on certain public careers, the Supreme Court always maintained that when the administrative career law or the judicial career law were not in force, public servants could be freely appointed and dismissed. Before December 1990 there was no administrative career law; therefore, the relations between public servants and the State agencies were governed by general rules and by some special rules of an administrative nature established usually in the internal regulations and in the laws that regulated certain

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