Layno v. De la Cruz
REITERATIONFacts
The Antecedents: Lianga Bay Logging Co., Inc. (plaintiff) filed a complaint against Hernando Layno, Delfin Cueto, Enrique Layno, Jr., and Young Men Labor Union Stevedores (defendants). The plaintiff alleged that the defendants, through threats and intimidation, demanded the cancellation of its stevedoring contract with Diatagon Arrastre Co., Inc. (Diatagon) so that members of the Young Men Labor Union could undertake the loading of export logs. The defendants allegedly threatened to prevent the plaintiff from exporting its logs, with the town mayor, defendant Layno, threatening to use the town police in favor of the Union, causing irreparable damage to the plaintiff. Diatagon had employed workers affiliated with the Diatagon Arrastre Workers' Union. Procedural History: The Court of First Instance of Surigao del Sur issued a writ of preliminary injunction at the instance of Lianga Bay Logging Co., Inc., enjoining the defendants from threatening, preventing, interfering, or molesting the plaintiff and Diatagon in their stevedoring and arrastre operations. The defendants moved to dissolve the injunction, alleging lack of jurisdiction, that the case fell under the exclusive jurisdiction of the Court of Industrial Relations, and that Section 9(d) of Republic Act No. 875 was not followed. After hearing evidence, the court below declined to lift the injunction, finding existing contracts between Lianga Bay Logging Company and Diatagon, and between Diatagon and the Diatagon Arrastre Workers' Union. A motion for reconsideration was denied. The Petition: The defendants resorted to the Supreme Court via a petition for certiorari, questioning the validity of the injunction for lack of jurisdiction and non-observance of the conditions prescribed by Section 9 of the Industrial Peace Act (R.A. No. 875).
Issue(s)
Whether the Court of First Instance has jurisdiction over the case, considering the allegations of threats and intimidation and the applicability of the Industrial Peace Act. Whether the issuance of the writ of preliminary injunction was proper.
Ruling
The Supreme Court dismissed the petition for certiorari and found no merit in the petition. The writ of preliminary injunction prayed for was not issued due to the petitioners' failure to post the requisite bond, thus no dissolution thereof was required.
Ratio Decidendi
On the jurisdiction of the Court of First Instance and the applicability of the Industrial Peace Act: The Court held that the demand made by the petitioners did not constitute a labor dispute as defined in Section 2 of the Industrial Peace Act. The petitioners' answer in the court below merely indicated a notice to the rival union that the Young Men Labor Union would henceforth undertake the loading of logs, but did not claim any demand made on the respondent Logging Company or the Diatagon Arrastre Company, other than that its members be substituted for those of the union with which a contract existed. The petitioners sought not a change in working terms or conditions, nor the representation of employees, but rather that its members be hired as stevedores in place of the members of the Diatagon Arrastre Workers' Union, notwithstanding an existing contract. The Court emphasized that the definitions of "labor disputes" in the Act must be confined to cases involving the exercise of freedom of action of employees in their freedom of association and designation of bargaining representatives. In this case, the Young Men Labor Union made no demand for better terms or conditions of work, nor did it seek the right to represent the workers already employed; instead, it wanted them discharged and replaced by its own members. Therefore, there was no controversy over terms, tenure, or conditions of employment, or over representation of employees that called for the application of the Industrial Peace Act. On the alleged unfair labor practice and jurisdiction: The Court stated that a mere charge or allegation of unfair labor practice, such as discrimination in favor of workers affiliated with the Arrastre Workers' Union, does not suffice to oust the jurisdiction of the court of first instance. There was a total absence of evidence that the acts complained of were actually committed, or that an unfair labor practice charge had been made or was pending in the Court of Industrial Relations. The petitioners failed to submit any evidence in the court of first instance to support their motion to lift the injunction, nor did they substantiate their charges regarding the expiration of the permit of the Diatagon Arrastre Workers' Union or that it was company-dominated. Consequently, the allegations did not divest the Court of First Instance of its jurisdiction.
Main Doctrine
A demand for the substitution of union members in place of existing contracted workers, without seeking a change in working terms or conditions or representation, does not constitute a labor dispute within the meaning of the Industrial Peace Act, thus not ousting the Court of First Instance of its jurisdiction.