National Mines v. Ilao
REITERATIONFacts
1. The Antecedents: In 1956, the Camarines Norte Confederation of Miners and Labor Association was certified as the exclusive bargaining representative for employees of the Paracale-Gumaus Consolidated Mining Company, Inc. A closed-shop agreement was entered into on December 19, 1959, effective January 1, 1960, stipulating that only members in good standing of the Confederation would be employed, and any employee expelled or losing good standing would be dismissed. Subsequently, on March 28, 1960, the Confederation requested the dismissal of an employee, Jorge Patinio, for no longer being a member, which the Company complied with two days later. 2. Procedural History: On February 16, 1960, the National Mines and Allied Workers' Union filed a petition for certification election with the Court of Industrial Relations (CIR), alleging it represented the majority of the Company's employees and that the Confederation no longer held their confidence. Following Patinio's dismissal, the National Mines and Allied Workers' Union filed an unfair labor practice complaint against the Company, its superintendent, the Confederation, and its president on April 5, 1960. On April 8, 1960, the Company filed an action for injunction in the Court of First Instance of Camarines Norte, seeking to restrain the National Mines and Allied Workers' Union from picketing and interfering with its closed-shop agreement. The Court of First Instance issued an ex-parte preliminary injunction the next day. 3. The Petition: The National Mines and Allied Workers' Union filed a petition for certiorari with preliminary injunction with the Supreme Court, seeking to annul the preliminary injunction issued by the Court of First Instance and to prohibit the judge from further cognizance of the case. The petitioner argued that the Court of First Instance lacked jurisdiction to issue the injunction, given the pending certification election and unfair labor practice proceedings in the CIR, which had exclusive jurisdiction over such matters. Furthermore, the petitioner contended that even if jurisdiction existed, the injunction was improperly granted without a hearing and evidence, contrary to the requirements of Republic Act 875, and that the temporary restraining order exceeded the permissible five-day duration.
Issue(s)
Whether the Court of First Instance of Camarines Norte had jurisdiction to issue an anti-picketing injunction in relation to pending proceedings before the Court of Industrial Relations. Whether the preliminary injunction was issued in accordance with the Rules of Court and Republic Act 875.
Ruling
The Supreme Court held that the respondent judge (Court of First Instance) had no jurisdiction over the subject matter of Civil Case No. 1207. Consequently, the writ of preliminary injunction issued ex parte in said case is declared void. Costs were assessed against the respondents, except the respondent judge.
Ratio Decidendi
On the jurisdiction of the Court of First Instance to issue an anti-picketing injunction: The Court ruled that the respondent judge erred in issuing the ex parte writ of preliminary injunction. At the time of the issuance, there were two pending proceedings before the Court of Industrial Relations: one for certification election and another for unfair labor practice. These matters fall under the exclusive jurisdiction of the CIR. Therefore, the Court of First Instance lacked the jurisdiction to issue an anti-picketing injunction, whether preliminary or final, concerning the subject matter of these CIR cases. The Court cited United Pepsi-Cola Sales Organization, etc. vs. Canizares (G.R. No. L-12294, Jan. 23, 1958) in support of this principle. On the procedural requirements for issuing a preliminary injunction: Even assuming, arguendo, that the CFI had jurisdiction over the principal action and the petition for preliminary injunction, it could not have issued the writ merely by following the provisions of Rule 60, Section 6 of the Rules of Court. Instead, it should have complied with Section 9(d) of Republic Act 875. This section mandates that the court must set the petition for hearing and receive evidence before issuing such a writ. The records show that this procedural requirement was not met in the present case, as the injunction was issued ex parte. Furthermore, any temporary restraining order issued under Section 9(d) of RA 875 is effective only for five days and becomes void thereafter by operation of law, as reiterated in the cited United Pepsi-Cola case.
Main Doctrine
A Court of First Instance has no jurisdiction to issue an anti-picketing injunction, whether preliminary or final, concerning matters that fall within the exclusive jurisdiction of the Court of Industrial Relations, such as certification election and unfair labor practice cases.