Naric Worker's Union v. Alvendia
REITERATIONFacts
The Antecedents: The underlying dispute arose from a strike by the Naric Worker's Union and its officers against the National Rice and Corn Corporation (NARIC). The union allegedly blocked the gates of NARIC's offices, threatening violence and bodily harm to those crossing their picket lines. NARIC filed a complaint for damages and sought a preliminary injunction to prevent these actions. Procedural History: NARIC filed a complaint in the Court of First Instance of Manila (Civil Case No. 36353) on May 26, 1958. The respondent judge, Carmelino Alvendia, issued an ex parte order for a preliminary injunction on the same day, which was later signed by Judge Bonifacio Ysip on May 27, 1958. The petitioners moved to dismiss the case, arguing that the Court of First Instance lacked jurisdiction because the dispute involved an unfair labor practice case exclusively cognizable by the Court of Industrial Relations. Their motion to dismiss and subsequent motion for reconsideration were denied by the respondent judges. The Petition: The petitioners, the Naric Worker's Union and its officers, filed this petition for certiorari with prohibition with the Supreme Court. They contend that the Court of First Instance has no jurisdiction over the case as it stems from a labor dispute involving unfair labor practices, which falls under the exclusive jurisdiction of the Court of Industrial Relations. They argue that despite NARIC being a government instrumentality, its activities are not purely governmental, and thus, the prohibition against strikes in the government does not apply. Furthermore, they assert that any acts of violence during the strike should be addressed by the Industrial Court, which has exclusive jurisdiction over such matters, including injunctions related to unfair labor practices.
Issue(s)
Whether the Court of First Instance has jurisdiction over a labor dispute involving alleged acts of violence and obstruction arising from a strike, when an unfair labor practice case is pending before the Court of Industrial Relations. Whether the National Rice and Corn Corporation (NARIC), being an instrumentality of the government, is precluded from strikes under Section 11 of Republic Act No. 875.
Ruling
The restraining orders complained of are set aside, and the complaint is ordered dismissed, without prejudice to the National Rice and Corn Corporation's seeking whatever remedy it is entitled to in the Court of Industrial Relations.
Ratio Decidendi
On the jurisdiction of the Court of First Instance over labor disputes involving unfair labor practices: The Supreme Court reiterated that courts of first instance have no jurisdiction in cases that grow out of labor disputes involving unfair labor practices. Such cases are exclusively cognizable by the Court of Industrial Relations. This exclusivity applies even if the dispute involves acts of violence, intimidation, and coercion, as these acts fall within the purview of Section 9(d) of Republic Act No. 875, which may be enjoined by the CIR. The Court emphasized that the reason for this rule is that picketing and strikes may be mere incidents or consequences of the unfair labor practice, making it proper for the court having jurisdiction over the main case (the CIR) to issue injunctions upon cognizance of all relevant facts. Therefore, even if the petitioning union was declared in default in the lower court, this did not affect the merits of the case due to the lack of jurisdiction. On the applicability of the prohibition against strikes in the government to NARIC employees: The Court held that while NARIC is an instrumentality of the government, its activities are not purely or exclusively governmental. The proviso of Section 11 of Republic Act No. 875 clearly limits the prohibition to "employees employed in governmental functions and not to those employed in proprietary functions of the Government." Since the work of the union members primarily involved hauling goods at NARIC's warehouses, barges, and piers, it bore only a remote relation to the governmental functions of the corporation. Consequently, the union members were not covered by the prohibition against strikes. The Court stressed that restrictions on workers' basic right to collective action are to be strictly construed.
Main Doctrine
Courts of First Instance have no jurisdiction over labor disputes involving unfair labor practices, which are exclusively cognizable by the Court of Industrial Relations, even if acts of violence are involved, as the remedy to enjoin such acts lies with the Industrial Court.