Victorias Milling Co. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Petitioner Victorias Milling Company, Inc. (VMCI) operates a sugar central and owns several sugar cane plantations. Respondent Free Visayan Workers (Union) is a labor organization with members employed by VMCI in its haciendas and nursery. On May 9, 1958, the Union submitted proposals for a collective bargaining contract. VMCI replied on July 29, 1958, refusing to enter into a contract, alleging that the Industrial Peace Act (Republic Act No. 875) is not applicable to agricultural workers. Procedural History: The Union filed a charge of Unfair Labor Practice against VMCI with the Court of Industrial Relations (CIR). The CIR prosecutor filed a complaint. VMCI filed a motion to dismiss, questioning the applicability of RA 875. The CIR denied the motion to dismiss and ordered VMCI to answer. A motion for reconsideration was denied. VMCI then instituted the present action for prohibition. The Petition: The core issue presented to the Supreme Court is whether the Industrial Peace Act applies to agricultural workers.
Issue(s)
Whether the Industrial Peace Act (Republic Act No. 875) applies to agricultural workers. Whether the Court of Industrial Relations has jurisdiction over unfair labor practice cases involving agricultural workers.
Ruling
The petition for prohibition is granted. The order denying the motion to dismiss is set aside, and the respondent Court of Industrial Relations is ordered to desist from taking any further action in Case No. 50-ULP-Iloilo. The respondent Union is reserved the right to file their complaint in the proper court.
Ratio Decidendi
On the applicability of the Industrial Peace Act to agricultural workers: The Supreme Court reiterated that agricultural laborers are exempted from the definition of 'employee' under Section 2(d) of the Industrial Peace Act (Republic Act No. 875). This exemption was previously stated in Boy Scouts of the Philippines v. Julian Araos. The Court emphasized that the nature of the work classifies a worker; those devoted to purely agricultural work are considered agricultural laborers. The members of the respondent Union are engaged in planting and harvesting sugar canes and other chores incidental to ordinary farming operations, thus classifying them as agricultural laborers. On the jurisdiction over unfair labor practice cases involving agricultural workers: The Court held that matters pertaining to the relationship of tenant and landlord, or controversies arising as an incident of their relationship, fall under the exclusive jurisdiction of the Court of Agrarian Relations (CAR). This is consistent with the purpose of the CAR, which was created for the enforcement of all laws and regulations governing the relation of capital and labor on all agricultural lands. The subsequent enactment of Republic Act No. 2263, granting agricultural workers the right to file such actions, merely confirms the CAR's jurisdiction. Therefore, the CIR improperly assumed jurisdiction over the case, as it falls under the exclusive jurisdiction of the agrarian court, as affirmed in Santos v. CIR, et al. and Hacienda Esperanza, et al., v. CIR, et al.
Main Doctrine
The Industrial Peace Act (Republic Act No. 875) does not apply to agricultural workers. Matters pertaining to the relationship of tenant and landlord, or controversies arising from their relationship, fall under the exclusive jurisdiction of the Court of Agrarian Relations.