National Association of Trade Unions v. Bayona
REITERATIONFacts
The Antecedents: Members of the National Association of Trade Unions (NATU), employed at People's Bank and Trust Co., declared a strike and set up picket lines. The Bank instituted Civil Case No. 33913 against the Association of Bank Employees (NATU) and its officers, alleging illegal acts causing substantial and irreparable injury, and seeking a temporary restraining order without notice. The Bank claimed public officers were unable to furnish adequate protection and that it had no adequate remedy at law, citing PAFLU vs. Tan. Procedural History: On October 3, 1957, the Court of First Instance of Manila, through respondent Judge Froilan Bayona, issued a writ of preliminary injunction based on the Bank's sworn complaint and an affidavit, without holding a hearing or taking testimony. The injunction restrained the defendants from engaging in mass, violent, boisterous, or unlawful picketing, coercing customers or employees, preventing ingress/egress of goods, interfering with security guards, and impeding the bank's business, until further order. The Petition: On October 5, 1957, NATU filed a petition for certiorari and prohibition, alleging that respondent Judge exceeded his jurisdiction and committed grave abuse of discretion in issuing the writ and taking cognizance of the case, as it involved a labor dispute cognizable only by the Court of Industrial Relations and violated Section 9(d) of Republic Act No. 875.
Issue(s)
Whether the Court of First Instance has jurisdiction over the labor dispute. Whether the writ of preliminary injunction was validly issued without a prior hearing and sworn testimony.
Ruling
The petition for certiorari is granted, but the writ of prohibition is denied. The writ of preliminary injunction issued by the respondent Judge on October 3, 1957, is declared null and void.
Ratio Decidendi
On the jurisdiction of the Court of First Instance: The Court reiterated its rulings in PAFLU vs. Tan and PAFLU vs. Barot, holding that Courts of First Instance have jurisdiction over labor disputes when the dispute does not affect an industry indispensable to the national interest (certified by the President), nor involve minimum wage, hours of employment, or unfair labor practices, as defined under Republic Act No. 875. In this case, the dispute did not fall under these exceptions, thus granting jurisdiction to the Court of First Instance. On the validity of the ex parte injunction: The Court found that the respondent Judge exceeded his jurisdiction in issuing the restraining order based solely on the allegations of the verified complaint without taking the testimony of any witness. Citing Reyes vs. Tan and PAFLU vs. Barot, the Court emphasized that Section 9(d) of Republic Act No. 875 requires testimony under oath, sufficient to justify a temporary injunction upon hearing after notice. The issuance of the injunction without a hearing and without sworn testimony, as required by law, renders the injunction void. The Court noted that the injunction was issued for an indefinite period ("until further orders"), which also violated the five-day limit for ex parte restraining orders under Section 9(d) of Republic Act No. 875, as clarified in United Pepsi-Cola Sales Organization vs. Cañizares.
Main Doctrine
A writ of preliminary injunction in a labor dispute, issued ex parte by a Court of First Instance without prior hearing and without taking sworn testimony, is void for not having been issued in accordance with Section 9(d) of Republic Act No. 875.