Caltex Employees Assn. v. Lucero
REITERATIONFacts
The Antecedents: The Caltex Refinery Employees Association-PAFLU (union) delivered a strike notice on March 25, 1959. Due to intervening holidays, the notice was officially recorded on March 30, 1959. Conciliation conferences were held, during which the union asserted its right to strike after April 23, 1959, based on a 30-day period from March 25, 1959. Caltex (Philippines) Inc. contended the 30-day period commenced on March 30, 1959. The union confirmed its threat to strike in a letter dated April 13, 1959. Procedural History: Alleging a violation of Section 14 of Republic Act 875 due to the union's threat to strike within the cooling-off period, the company filed a petition for injunction with the Court of First Instance of Manila. The company sought an ex parte restraining order to prevent substantial and irreparable injury to its property. On April 23, 1959, the court issued the restraining order, enjoining the union from striking before April 30, 1959, upon the company's posting of a P5,000.00 bond. The union's motion for reconsideration was denied. The Petition: The union filed a petition for certiorari with preliminary injunction before the Supreme Court, assailing the restraining order issued by the respondent court. The union argued that under Section 9(a) of Republic Act 875, no court can issue any restraining order against a planned strike. Alternatively, it contended that even if such an order could be issued to prevent an unlawful strike, it could only be done after complying with the procedural requirements of Section 9(d) of the same Act. The company maintained that courts are authorized to issue restraining orders when a projected strike is unlawful and would result in irreparable and substantial injury to the employer's property.
Issue(s)
Whether the Court of First Instance of Manila had the jurisdiction to issue an ex parte restraining order enjoining the union from declaring a strike. Whether the issuance of the restraining order complied with the procedural requirements mandated by Republic Act 875.
Ruling
The petition is granted. The restraining order issued by the respondent court on April 23, 1959, is set aside. Costs are against respondent Caltex (Philippines) Inc.
Ratio Decidendi
On Issue 1: The Supreme Court held that under Section 9(a) of Republic Act 875, no court has jurisdiction to issue any restraining order, whether temporary or permanent, in any case growing out of a labor dispute. This prohibition covers acts such as ceasing or refusing to perform work or to remain in any relation of employment. The only exception is when the President of the Philippines certifies a labor dispute in an industry indispensable to the national interest to the Court of Industrial Relations, as provided in Section 10 of the same Act. Therefore, the court's power to issue restraining orders in labor disputes is severely limited by statute, and the general prohibition applies unless the specific exception is met. On Issue 2: Even if a restraining order could be issued to prevent an unlawful strike or one causing substantial and irreparable injury to the employer's property, the Supreme Court emphasized that such an order must strictly comply with the procedural requirements laid down in Section 9(d) of Republic Act 875. These requirements include a hearing where due notice is given to both parties, testimony of witnesses is taken with the opportunity for cross-examination, and a showing that public officers charged with protecting the petitioner's property are unable or unwilling to furnish adequate protection. The Court reiterated its previous ruling that an ex parte grant of a restraining order in a labor dispute is impermissible, as it violates the procedural safeguards established by the law. Since the respondent court failed to follow this procedure, the restraining order it issued was deemed illegal and unsustainable.
Main Doctrine
Under Section 9(a) of Republic Act 875, no court has jurisdiction to issue any restraining order, temporary or permanent, in a labor dispute, except when the President certifies a dispute in an industry indispensable to the national interest to the Court of Industrial Relations under Section 10. Furthermore, even if a strike is potentially illegal or may cause irreparable injury, any restraining order must comply with the procedural requirements of Section 9(d), which mandates a hearing with due notice to both parties, the taking of testimony, and the opportunity for cross-examination, and a showing that public officers are unable or unwilling to provide adequate protection.