Benguet Consolidated Mining Co. v. Coto Labor Union
REITERATIONFacts
The Antecedents: The Coto Labor Union declared a strike against Benguet Consolidated Mining Company. The union set up pickets along the company road and railroad tracks. The company alleged that the strikers barricaded these routes, used coercion, threats, and violence to prevent passage of trains carrying ore and vehicles with necessities. It was also alleged that a company foreman was stabbed to death by strikers when he attempted to drive an ore train. The company claimed inadequate protection from Constabulary soldiers due to legal prohibitions against police interference in picketing. Procedural History: The company filed a complaint for injunctive relief in the Court of First Instance (CFI) of Manila. The CFI granted a preliminary injunction ex parte, restraining the union from obstructing the company's road and railroad tracks. The CFI later qualified the injunction to not prohibit peaceful picketing. While the case and contempt proceedings were pending, the Supreme Court issued rulings holding that the Court of Industrial Relations (CIR) has exclusive jurisdiction over cases involving unfair labor practice. Invoking these rulings, the defendants moved for dismissal, arguing the subject matter fell under the CIR's exclusive jurisdiction due to its connection with pending unfair labor practice cases. The CFI granted the motion to dismiss. The Petition: The plaintiff-appellant appealed the dismissal order, contending that the acts sought to be enjoined were unrelated to the strike.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue an injunction in a matter connected with an unfair labor practice case pending before the Court of Industrial Relations. Whether the preliminary injunction issued ex parte was validly issued considering the procedural requirements of Republic Act 875. Whether the acts sought to be enjoined were related to the strike declared by the union.
Ruling
The Supreme Court affirmed the order of the Court of First Instance dismissing the plaintiff's complaint. The Court held that the CFI acted without jurisdiction in issuing the injunction and in trying the case, as the matter fell within the exclusive jurisdiction of the Court of Industrial Relations. The preliminary injunction was also declared null and void for having been issued in disregard of the procedural requirements of Republic Act 875.
Ratio Decidendi
On the jurisdiction of the Court of First Instance: The Court reiterated its established jurisprudence that the Court of Industrial Relations (CIR) has exclusive jurisdiction over cases involving unfair labor practice. It was undisputed that unfair labor practice cases between the parties were already pending before the CIR when the strike was declared and the injunctive relief was sought. The Court cited the case of Lakas Ng Pagkakaisa Sa Peter Paul et al., vs. Judge Victoriano et al., (G. R. No. L-9290, January 14, 1958), which held that a court a quo has no jurisdiction to try a case if it is already involved in cases submitted to the industrial court, to avoid multiplicity of actions. The Court emphasized that any injunctive relief against acts of violence could be obtained from the CIR, which possesses ample power to act on such matters. On the validity of the preliminary injunction: The Court found the writ of preliminary injunction issued by the court a quo to be illegal. This was because it was issued in disregard of the procedure prescribed in Section 9(d) of Republic Act 875. This section mandates a hearing, presentation of testimonial evidence, and an opportunity for cross-examination by both parties, along with other legal requirements to be established and stated in the court's order. Since these procedures were not followed, the writ of preliminary injunction was deemed null and void. On the relation of the acts to the strike: The Court found the appellant's contention that the acts sought to be enjoined were unrelated to the strike to be without merit. The complaint clearly described the acts of barricading the road and railroad tracks, and using coercion, threat, intimidation, force, and violence to prevent passage, as a consequence of the strike. The purpose of these acts was to prevent ore shipment and to retaliate against non-striking employees by starving them. The Court noted that the defendants themselves, in their answer, alleged as a special defense that the acts sought to be restrained arose out of the strike. While a statement in a motion to dissolve the injunction suggested a lack of relation, the Court clarified that this referred specifically to the alleged killing of a foreman, not a sweeping admission that all acts were unconnected to the strike.
Main Doctrine
A Court of First Instance lacks jurisdiction to issue an injunction in matters connected with an unfair labor practice case pending before the Court of Industrial Relations, especially when the injunction is sought without adhering to the procedural requirements of Republic Act 875, including a hearing and presentation of testimonial evidence.