Federacion Obrera v. Mojica
REITERATIONFacts
The Antecedents: Respondent Liwayway Gawgaw & Coffee Repacking filed a complaint for damages with a writ of preliminary injunction against petitioner Federacion Obrera de la Industria Tabaquera y Otros Trabajadores de Filipinas (FOITAF). Respondent Judge granted the plea for preliminary injunction. Procedural History: Petitioner FOITAF filed a motion to dismiss the complaint and to quash the writ, asserting that two unfair labor practice cases were pending before the Court of Industrial Relations (CIR). Respondent Judge denied the motion, stating that the court had jurisdiction over the subject matter. The Petition: Petitioner filed a petition for certiorari and prohibition with preliminary injunction, assailing the respondent Judge's orders for acting without or in excess of jurisdiction, or with grave abuse of discretion.
Issue(s)
Whether the respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion in taking cognizance of the complaint for damages with preliminary injunction. Whether the respondent Judge erred in denying the motion to dismiss and to quash the writ of preliminary injunction.
Ruling
The petition is granted. A writ of certiorari shall issue to annul the orders of July 16, 1965, and August 28, 1965. The respondent Judge, or his successor, is ordered to desist from taking further action in Civil Case No. 2631-P, as the matter is outside his jurisdiction. Costs are against respondent Liwayway Gawgaw & Coffee Repacking.
Ratio Decidendi
On the issue of jurisdiction over unfair labor practice cases: The Supreme Court reiterated its consistent holding that under the Industrial Peace Act, unfair labor practice cases fall within the exclusive competence of the Court of Industrial Relations. The respondent Judge paid scant heed to this unbroken line of authority by assuming jurisdiction over a matter vested by law in the CIR. Even if no unfair labor practice suit had been filed at the time an injunction was sought in the court of first instance, the latter would still have no jurisdiction if it is shown that the labor dispute arose out of unfair labor practices committed by any party. The distinction between an unfair labor practice "charge" and an unfair labor practice "complaint" is irrelevant; the CIR's jurisdiction remains as long as unfair labor practice is involved. Therefore, the respondent Judge's actuation in taking cognizance of the complaint and issuing the injunction was a clear case of acting without or in excess of jurisdiction, or with grave abuse of discretion. On the denial of the motion to dismiss and to quash the writ: The respondent Judge should have properly disposed of the matter by dissolving the writ of preliminary injunction and dismissing the complaint. The admission by respondent Liwayway Gawgaw & Coffee Repacking that the cases mentioned were "charges" or complaints pending preliminary investigation by CIR-Prosecutors, and not before the Court itself, was fatal to the assumption of jurisdiction by the respondent Judge. This admission, coupled with the established jurisprudence, should have prompted the respondent Judge to dismiss the case and quash the writ, rather than deny the motion.
Main Doctrine
The Court of Industrial Relations has exclusive jurisdiction over unfair labor practice cases, and courts of first instance act without or in excess of jurisdiction, or with grave abuse of discretion, in taking cognizance of such cases or issuing injunctions related thereto.