Abo v. Philame (KG) Employees & Workers Union
REITERATIONFacts
The Antecedents: Plaintiffs, employees of Philippine American Embroideries, Inc., filed a complaint alleging that from March 24, 1961, to May 6, 1961, individual defendants, acting as officers and/or members of defendant labor unions, by concerted action, force, violence, and intimidation, prevented plaintiffs from entering the KG Department premises. Plaintiffs sought damages for lost wages, moral damages, exemplary damages, and attorney's fees. Procedural History: Defendants filed a motion to dismiss, asserting lack of jurisdiction, amicable settlement of the labor dispute, and pendency of an unfair labor practice case before the Court of Industrial Relations (CIR). The Court of First Instance (CFI) dismissed the complaint for lack of jurisdiction, citing Sections 4(b)(1) and 24 of the Industrial Peace Act (Republic Act No. 875). The Petition: Plaintiffs appealed, contending that the CFI erred in dismissing the complaint, arguing that the acts described did not constitute unfair labor practice as no right of self-organization was alleged.
Issue(s)
Whether the Court of First Instance erred in dismissing the complaint on the ground of lack of jurisdiction. Whether the acts described in the complaint constitute unfair labor practice under Section 4(b)(1) of the Industrial Peace Act.
Ruling
The judgment of the lower court is reversed, and the record of the case is remanded to the court of origin for further proceedings. Costs are against the defendants-appellees.
Ratio Decidendi
On whether the Court of First Instance erred in dismissing the complaint on the ground of lack of jurisdiction: The Supreme Court held that the CFI erred. The jurisdiction of a court is determined by the allegations in the complaint alone. The Court cited Campos Rueda Corp. v. Bautista and Administrator of Hacienda Luisita Estate v. Alberto to support the principle that jurisdiction cannot be postponed based on potential evidence or determined by the opposing party's evidence. The lower court's conclusion that the acts constituted unfair labor practice was based on union evidence tending to prove a labor dispute, which is contrary to the rule that jurisdiction is determined from the complaint's allegations. Furthermore, Section 24 of the Industrial Peace Act, which provides protection for acts done in furtherance of an industrial dispute, cannot be invoked because the complaint does not allege that the charged acts were in furtherance of an industrial dispute. The mere fact that the defendants are union officers or members does not automatically mean their acts were in furtherance of such a dispute. On whether the acts described in the complaint constitute unfair labor practice under Section 4(b)(1) of the Industrial Peace Act: The Supreme Court found that the acts described in the complaint did not necessarily constitute unfair labor practice as defined by Section 4(b)(1) of the Industrial Peace Act. This section prohibits a labor organization or its agents from restraining or coercing employees in the exercise of their rights under Section 3, which pertains to the right to self-organization. The complaint alleged acts of force, violence, and intimidation preventing employees from entering the premises. However, the Court noted that the complaint did not explicitly state that these acts were committed in connection with a labor dispute or in restraint of the right to self-organization. The lower court's reliance on evidence of a labor dispute to classify the acts as unfair labor practice was misplaced, as jurisdiction should be determined solely on the allegations in the complaint.
Main Doctrine
The jurisdiction of a court is determined by the allegations in the complaint, and not by evidence presented by the opposing party, nor can the consideration of a motion to dismiss on the ground of lack of jurisdiction be postponed in the hope that evidence may yield other qualifying data. Acts described in a complaint do not constitute unfair labor practice if it is not evident from the complaint that such acts were committed in furtherance of an industrial dispute.