Union v. Marcos
REITERATIONFacts
The Antecedents: The BCI Employees and Workers Union (PAFLU) filed a notice of strike on December 28, 1962, and Benguet Consolidated, Inc. (BCI) filed a notice of lockout simultaneously. Conciliation conferences failed. On March 3, 1963, the union declared a strike in three mining areas of BCI, followed by picketing. Procedural History: On March 6, 1963, BCI filed a petition with the Court of First Instance (CFI) of Baguio seeking to restrain the picketing. The union filed a motion to dismiss on March 7, 1963, citing the pendency of unfair labor practice cases before the Court of Industrial Relations (CIR) and non-compliance with jurisdictional requirements. The CFI denied the motion. On March 12, 1963, the CFI issued a preliminary injunction after a hearing. The Petition: On March 13, 1963, the union filed a petition for certiorari with preliminary injunction with the Supreme Court, assailing the jurisdiction of the CFI.
Issue(s)
Whether the Court of First Instance of Baguio had jurisdiction to entertain the petition filed by Benguet Consolidated, Inc. to restrain picketing arising from a labor dispute already pending before the Court of Industrial Relations. Whether the labor dispute involved in the petition before the Court of First Instance was the same as those pending before the Court of Industrial Relations.
Ruling
The Supreme Court granted the petition for certiorari, declared the respondent judge without jurisdiction to act in Civil Case No. 1240, and made the preliminary injunction permanent. Costs were against respondent Benguet Consolidated, Inc.
Ratio Decidendi
On the jurisdiction of the Court of First Instance: The Court held that the Court of First Instance of Baguio lacked jurisdiction to entertain the petition filed by Benguet Consolidated, Inc. The petition was precipitated by a strike and picketing arising from a labor dispute. The record clearly showed that this labor dispute was already the subject of two unfair labor practice cases pending before the Court of Industrial Relations (CIR), Case No. 2363-ULP and Case No. 3289-ULP, which were filed much earlier than the petition in the CFI. The CIR's jurisdiction over unfair labor practice cases is exclusive, as provided by Section 5(a) of Republic Act 875. Therefore, any action filed in a regular court that is interwoven with cases pending before the CIR is considered outside the jurisdiction of the regular courts. This principle is necessary to avoid multiplicity of suits and to ensure that the CIR, which is vested with the power to act on such matters, can effectively resolve labor disputes. Even if the petition involved averments of violence, intimidation, and coercion, the proper venue for seeking injunctive relief in such circumstances remains the Industrial Court. On the identity of the labor dispute: The Court found that the labor dispute involved in all the cases was the same. The unfair labor practice cases before the CIR were based on alleged dismissals of union members due to their union affiliation or activities. The strike called by the union, which led to the picketing sought to be enjoined, expressly cited "discrimination against union members in the enforcement of disciplinary actions" as one of its reasons. This clearly indicated that the issues raised in the CFI petition were intrinsically linked to and arose from the same underlying labor dispute that was already under the jurisdiction of the CIR. Consequently, the CIR had already acquired jurisdiction over the dispute when the petition was filed with the CFI, rendering the latter court without authority to proceed.
Main Doctrine
The Court of Industrial Relations has exclusive jurisdiction over labor disputes, including those involving unfair labor practices and acts of violence, intimidation, and coercion arising therefrom, to the exclusion of regular courts.