62 According to the Labour Code, the dismissal of leaders with labour union powers subject to such rules, required authorisation in advance from the labour courts.33 The Administrative Code, and the organic law and the internal regulations of the institution governed the other public servants who were not covered by special laws where they worked. The employer was obliged to notify the worker, in advance and in writing, about the date of and cause for dismissal. Once the dismissal orders were issued, the workers had the right to file a reconsideration remedy with the same department that issued the orders, and an appeal remedy with the immediate superior, thus exhausting the governmental recourses. Thereafter, the workers had the possibility to appear before the Third Section of the Supreme Court, which deals with matters of the administrative conflicts jurisdiction.34 Facts after the passing of Law 25 n. on December 14, 1990, the Legislative Assembly passed Law 25.35 The cited Law 25 was published in the Official Gazette of Panama N° 21.687 of December 17, 2000; and Labour Code of the Republic of Panama of 1972, second edition, Mizrachi & Pujol S.A. publishers, 1996. 33 cfr. Labour Code of the Republic of Panama of 1972, second edition, Mizrachi & Pujol S.A. publishers, 1996; testimony of Manrique Mejía delivered before the Inter-American Court on January 26, 2000; and December 13, 1990, minutes of the Legislative Assembly pertaining to the discussion of the Law 25 draft bill. 34 cfr. report of the expert Maruja Bravo-Dutary, delivered before the Inter-American Court on January 27, 2000. 35 cfr. Law 25 of December 14, 1990, published in the Official Gazette of Panama N° 21.687 of December 17, 1990; testimony of Rogelio Cruz-Ríos delivered before the Inter-American Court on January 26, 2000; ; report of the expert Humberto Ricord, delivered before the Inter-American Court on January 26 , 2000; testimony of Marta de-León-de-Bermúdez delivered before the Inter-American Court on January 27, 2000; report of the expert Maruja Bravo-Dutary, delivered before the Inter-American Court on January 27, 2000; an article of the “La Estrella de Panamá” newspaper entitled "Endara's attitude against reconciliation," published December 16, 1990; an article of the “La Estrella de Panamá” newspaper entitled "Panamanian democracy being demolished," published December 16, 1990; an article of the “La Estrella de Panamá” newspaper entitled "Presidential advisors are the culprits," published December 19, 1990; an article of the “La Estrella de Panamá” newspaper entitled "Labour union leaders suspend hunger strike and accept mediation," published December 25, 1990; an article of the “La Estrella de Panamá” newspaper entitled "Passing of law leads to serious disturbances," published December 15, 1990; Cabinet Council Resolution N° 10 of January 23, 1991, published in the Official Gazette of Panama N° 21.718, of February 4, 1991; judgment of the Full Supreme Court of May 23, 1991, concerning the three unconstitutionality actions brought by Vicente Archibold-Blake in representation of Isaac Rodríguez; by Santander Tristán-Donoso et al.; and by Basilio Chong-Gómez in representation of Rolando Miller et al., against Law 25 of December 14, 1990; note CSJ-SNG-354-94 of October 3, 1994, from the Vice President Justice in charge of the Presidency of the Supreme Court of Panama, addressed to the Minister of Foreign Affairs of Panama; judgment of the Administrative Conflicts Section of the Supreme Court of June 21, 1993, in connection with the actions brought by Vicente Archibold-Blake in representation of Miguel Angel Osorio, Jaime Salinas-M., Giovanni E. Prado-S., Tomás A. Pretelt, Rubén D. Pérez-G., Sergio Ochoa-Castro, Sildee Ríos-de-Silva, Dorindo A. Ríos, Alidio Rivera, Sandra C. de-Romero, Ernesto RomeroAcosta, Isaac M.-Rodríguez, Fredys Pérez-M., Dony Arcesa Ramos-Quintero, Ricardo R. Ríos, Luis G. Risco-B., Ilka de-Sánchez, José Santamaría, Luis Arturo Sánchez, Enigno Saldaña, Teresa R. de-Sierra, Manuel Enrique Valencia, Christian Eliécer Pérez, Rodolfo G. Vence-R., Marisina del C. Ubillus-D., Rafael Tait-Yepes, Víctor Julio Soto, Cristóbal Segundo Jr., Elvira A. de-Solórzano, Enrique C. Sellhom-M., Rodolfo A. Wynter, Ricardo A. Trujillo-R., Luis Olmedo-Sosa-C., Sonia de-Smith, and Damiel S. Trejos-G.; "Preliminary report prepared by the Dismissed Workers' Committee concerning the obligations pending payment to the workers dismissed pursuant to Law 25 of December 14, 1990, in the Republic of Panama; Resolution of the Labour Union Freedom Committee in Case N° 1569 "Complaints against the Government of Panama submitted by the International Confederation of Free Labour Union Organisations (CIOSL), the

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