40 Supreme Court of Panama resolved the unconstitutionality complaint against Law 25 of 1990, it did not pronounce itself concerning the situation of the public servants dismissed in application of the law because, according to the legislation, the constitutional proceeding is purely of law and what is determined is whether in the confrontation between the rule and the act regarded unconstitutional there is some violation of the constitutional rules. Several factors were taken into account in the judgment for purposes of guaranteeing the due process. In the first place, that it was not a penal case, but a case where the appointing authority was given the possibility to terminate or declare non subsistent the appointment of a given public servant. Secondly, that it referred to employees not included into the administrative career. For the Justices it was a problem that involved disciplinary law, since there was a very clear distinction between penal guarantees, and the guarantees that related to a disciplinary proceeding. He feels that if in this case the resolution of the Cabinet Council would have been applied as a basis for some dismissal decision, the unconstitutionality of the resolution could have been alleged in a warning of unconstitutionality made by the attorney of the affected party. In this case the official to whom the warning would have been presented would have been obliged to consult the Supreme Court, in order for it to instruct, if it deemed that it was unconstitutional, its non application in the case. However, this was not done. In accordance with the impugnation system established by Law 25, the dismissed workers who were not in agreement with the action taken had the possibility to use the administrative mechanism through the administrative remedies of reconsideration and appeal, leaving the administrative conflicts jurisdiction open. The full jurisdiction administrative conflicts mechanism requires the filing of the complaint by the affected party; the transfer thereof to the same authority that performed the original action, in this case the official who ordered the dismissal; the transfer to the Attorney General of the Administration in defence of the legal order; and upon conclusion of this stage, or as part of the same process, the opening of the case to be proven, once the complaint is responded to by the authority who performed the contested action. He believes that five days are allowed for the parties to announce or to cite the evidence that they deem appropriate, including new evidence if they so desire. Upon conclusion of this stage to cite evidence, 30 days are allowed to produce it. The Third Administrative Conflicts Section of the Supreme Court existed since before December 1990, and it also acts as the Labour Cassation Court of Panama. He was not a member of the Third Administrative Conflicts Section of the Supreme Court, and therefore he was unable to hear cases where dismissal actions were contested in the administrative conflicts jurisdiction. While he was the Chief Justice, the full Supreme Court received constitutional guarantee protection remedies aimed against resolutions of the Conciliation and Decision Boards, which flatly rejected reinstatement actions proposed by public servants of the IRHE and the INTEL dismissed in application of Law 25. He had to be the reporter in a civil rights protection remedy action where the worker asserted that he had gone to the Conciliation and Decision Board and that it had rejected his action in limine without having taken it into consideration. The Supreme Court resolved to admit this civil rights protection remedy action and to order the Conciliation and Decision Board to take the action into consideration and to decide on its own competence after hearing the party affected. During his performance as Supreme Court Justice, he participated in the deliberation of judgments where international treaties were cited as law in force in Panama, as part of the constitutionality block. This doctrine was an effort that they made as members of a Supreme Court that was initiated amidst great many difficulties. A group of Supreme Court Justices had an interest in reconciling internal law with inter-American law. The constitutionality block doctrine became consolidated and is now very frequently applied by the