Reyes v. Tan
REITERATIONFacts
The Antecedents: Petitioners, employees of Master Shirt Company and members of the Kapisanan ng Mga Manggagawa ng Damit labor union, declared a strike on April 24, 1955, following the dismissal of a co-worker. They established a picket line outside the factory. Procedural History: On May 10, 1955, respondents, also employees of the same company but members of a rival union (Samahan ng Mga Manggagawa sa Master Shirt Company), filed a complaint before the Court of First Instance of Manila seeking a preliminary injunction. They alleged that the striking employees (petitioners) prevented them from taking meals at the factory through acts of coercion and violence, intercepted food supplies, and employed force and intimidation to prevent others from breaking the picket line. The Court of First Instance issued the writ of preliminary injunction on the same day, based solely on sworn affidavits, without a prior hearing, citing the respondents' right to eat and live. The Petition: Petitioners moved to dissolve the injunction the next day, May 11, 1955, arguing that the Court of First Instance lacked jurisdiction to issue injunctions in labor disputes under Republic Act No. 875 (Industrial Peace Act), which vests exclusive jurisdiction in such matters to the Court of Industrial Relations. The respondent judge denied their motion, prompting the filing of this petition for certiorari and prohibition.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue an injunction in a dispute involving admitted acts of unfair labor practices. Whether an ex parte preliminary injunction issued in a labor dispute based on mere affidavits is valid under Republic Act No. 875.
Ruling
The petition for certiorari is granted, and the writ of preliminary injunction issued by the respondent judge is declared null and void. Costs are against the respondent workers.
Ratio Decidendi
On Issue 1: The Court clarifies that the jurisdiction of the Court of Industrial Relations (CIR) is limited to specific categories, including cases involving an Unfair Labor Practice (ULP) as defined in Section 5(a) of Republic Act No. 875. In this case, both the petitioners and respondents admitted that the acts against which the injunction was sought—specifically coercion and intimidation during a strike—constitute unfair labor practices. Under prevailing jurisprudence, specifically PAFLU vs. Tan (G.R. No. L-9115), once a case involves an unfair labor practice, the jurisdiction to grant injunctive relief resides exclusively with the industrial court. Therefore, the Court of First Instance (CFI) lacked the subject matter jurisdiction to entertain the application for injunction. The admission by both parties regarding the nature of the acts as ULPs serves as the primary basis for divesting the ordinary court of its power to act on the matter. Consequently, the CFI should have dismissed the complaint or referred it to the CIR upon determining the nature of the labor dispute. On Issue 2: Even if the Court of First Instance (CFI) were assumed to have jurisdiction, the injunction issued is nonetheless void for failure to comply with the strict procedural mandates of Section 9(d) of Republic Act No. 875. The respondent judge erred in applying Rule 60, Section 6 of the Rules of Court, which allows for ex parte injunctions based on affidavits, because labor disputes are governed by the specific provisions of the Industrial Peace Act. Section 9(d) of RA 875 requires that an injunction be issued only after a hearing where testimony under oath is received and the parties are afforded the opportunity for cross-examination. The Court emphasized that an injunction issued on the basis of mere affidavits, without such a hearing, is an act in excess of jurisdiction and is legally ineffective. Furthermore, the statute provides that any temporary restraining order issued ex parte shall be effective for no longer than five days. Since the subject injunction was issued ex parte and remained in force beyond the five-day statutory limit without the required hearing, it became void by operation of law.
Main Doctrine
The Court of First Instance has jurisdiction to issue injunctions in labor disputes not falling within the exclusive jurisdiction of the Court of Industrial Relations under Republic Act No. 875. However, an ex parte injunction in a labor dispute, even if the court has jurisdiction, is void if issued without following the procedural requirements of Section 9(d) of Republic Act No. 875, which mandates a hearing and sworn testimony, and cannot be granted solely on affidavits.