United Restauror's Employees & Labor Union-Philippine Association of Free Labor Unions v. Torres
REITERATIONFacts
The Antecedents: Delta Development Corporation (Delta), owner of the Makati Commercial Center, leased portions thereof. The United Restauror's Employees & Labor Union-PAFLU (Union), composed of employees of Sulo Restaurant (a lessee), sought permission to picket on Delta's private property surrounding Sulo Restaurant. Delta denied the request, citing potential liability and the absence of an employer-employee relationship between Delta and the Union members. Procedural History: Despite the denial, the Union proceeded to picket on Delta's property. Delta filed a complaint for injunction with a prayer for a preliminary injunction. The Court of First Instance of Rizal issued the writ of preliminary injunction, which was later denied reconsideration. The Union filed a motion to dismiss, asserting lack of jurisdiction and that the case involved unfair labor practices falling under the Court of Industrial Relations (CIR). Without awaiting resolution of its motion to dismiss, the Union filed a petition for certiorari with the Supreme Court. The Petition: The Union filed a petition for certiorari, assailing the injunctive writ issued by the respondent judge. They argued that the judge acted without or in excess of jurisdiction, claiming the writ violated freedom of speech (right to picket), was issued without a hearing, and contravened Republic Act 875. They contended that jurisdiction properly belonged to the CIR as the case involved unfair labor practices. The Supreme Court issued its own writ of preliminary injunction.
Issue(s)
Whether the Court of First Instance acted without or in excess of jurisdiction in issuing a writ of preliminary injunction against the Union's picketing activities on private property. Whether the case has become moot and academic due to subsequent events.
Ruling
The petition for certiorari is dismissed, and the writ of preliminary injunction issued by the Supreme Court is dissolved, as the case has become moot and academic. The Court of First Instance did not act without or in excess of jurisdiction in issuing the preliminary injunction, as it was to protect property rights.
Ratio Decidendi
On Issue 1: The Court held that the Court of First Instance did not act without or in excess of jurisdiction in issuing the writ of preliminary injunction. The injunction was specifically aimed at preventing picketing on the private property of Delta Development Corporation, not at enjoining the picketing itself. Delta, as the owner of the property, has the right to protect its property from trespass and to prevent activities that could lead to liability, especially since it has no employer-employee relationship with the Union members. The Union's argument that the case involved unfair labor practices and thus fell under the exclusive jurisdiction of the Court of Industrial Relations was not the primary issue before the Court of First Instance, which was focused on the protection of property rights. The Court acknowledged that while picketing is a form of expression, it is not absolute and can be enjoined when it infringes upon the rights of others, such as property owners. On Issue 2: The Court found that the case had become moot and academic. This was primarily due to the results of a consent election held on October 4, 1965, which occurred after the Union had filed its petition for certiorari. In this election, a rival union, the Sulo Employees Labor Union (SELU), defeated the petitioner Union. As a consequence, SELU was certified as the exclusive bargaining representative of the employees of Sulo Restaurant. The Court reasoned that by losing the certification election, the petitioner Union lost its status as the majority union and, therefore, its right to demand collective bargaining. Consequently, its concerted activities, including picketing for the purpose of compelling the employer to bargain, became unlawful. The Court emphasized that the purpose of certification elections is to settle industrial disputes, and their outcomes must be respected. Allowing the minority union to continue picketing after losing an election would undermine the democratic will of the majority of the employees and render the election process meaningless.
Main Doctrine
A labor union's right to picket to compel an employer to bargain collectively ceases to be lawful once the union has been defeated in a certification election and has lost its majority status. The outcome of a certification election, conducted under the auspices of the Court of Industrial Relations (CIR), is binding on the participating parties and settles the issue of representation, rendering any subsequent picketing for the purpose of demanding collective bargaining unlawful and the labor dispute moot and academic.