34 penal and administrative guarantees. The first article of Law 25 says that those public employees who took part (the verb being used in the past tense), who carried out any activities with respect to the incidents that occurred in Panama, especially on December 4 and 5, 1990, must be punished with dismissal. It is evidently a completely retroactive text. By constitutional provision, the retroactivity of public order laws is permitted. It is very difficult to determine what the public order is. In his opinion, public order is the set of institutions and legal rules that refer to various aspects of State or private life. Article 43 of the Constitution is the generic rule on the subject of non-retroactivity of the law. Non-retroactivity and the penal guarantee prevail in Article 31; Article 43, however, permits retroactivity. In a “paragraph” of Article 2 of Law 25 it is established that they law should be complemented by the Cabinet Council, which was granted de power to determine which facts may be subject to the dismissal sanction. The law referred to actions such as attempts against democracy and the constitutional order, but it did not establish which those actions were, the determination thereof being delegated on the Cabinet Council. The Cabinet Council made such determination on January 23, 1999, improving the law, which was of a generic nature and which did not identify typical conducts. Said Council declared that collective and abrupt work stoppages in the public sector attempted against democracy and the constitutional order, and it established that all public servants who would have promoted, convoked, organised, participated in, or who would in the future promote, convoke, organise, etc., work stoppages without complying with the established procedures and restrictions would be subject to dismissal for cause. The Supreme Court declared constitutional the “paragraph” of Article 2 of Law 25 . Article 2 is so related to the nature of the fault that it would be impossible to apply the law outside the requirement that the Cabinet Council determine the typical conduct. There was no possibility to punish a worker without taking into consideration this typical element. However, dismissals were ordered before the Cabinet Council proceeded to determine the conduct pursuant to Resolution N° 10 of January 23, 1991, published in the Official Gazette on February 4, 1991. The Supreme Court felt that the granting of powers to the Cabinet Council to point out actions that attempted against democracy and the Constitution was unconstitutional, since such powers belonged to the judicial branch. This posed the serious problem of doubt being cast upon certain dismissal decisions when the question arose of what value could a law have when the Supreme Court is saying that the power to establish the typical punishable conduct is not legally founded? These workers had certain guarantees in their performance as State staff members, which were derogated by articles 4 and 5 of Law 25, as it established that such guarantees would not be applicable when found contrary to it. One of the final articles of Law 25 established that it would be valid until December 31, 1991, that is, that it was of temporary validity. This created a legal problem in that it was not known what would happen to the guarantees and laws reformed by Law 25 upon the expiration of its validity pursuant to its own mandate. In administrative conflicts proceedings the parties have the right to present evidence not yet presented or requested in the different administrative instances of the case. In 1990 and before the entering into force of the Administrative Career Law, public servants and Central Government workers facing a dismissal followed the regular administrative procedure. It consisted of the reconsideration recourse before the authority that had decreed the dismissal, except in the case that some special law would have granted competence to a head of a department. Once the administrative means were exhausted, the worker could use the administrative conflicts jurisdiction before the Third Section of the Supreme Court. Some of the persons affected by the dismissal judgments filed actions before the administrative conflicts jurisdiction, that is, the Third Section of the Supreme Court, which rejected the legality of all such actions.