Philippine Association of Free Labor Unions v. Salvador
REITERATIONFacts
1. The Antecedents: The underlying dispute involved a collective bargaining agreement between the Philippine Association of Free Labor Unions (PAFLU) and the Social Security System (SSS), which was adopted as a formal award by the Court of Industrial Relations (CIR) on August 5, 1966, and was effective until June 30, 1969. A disagreement arose concerning the implementation of certain provisions of this agreement. 2. Procedural History: PAFLU filed two petitions for certiorari challenging the jurisdiction of respondent Judge Joaquin M. Salvador and the CIR. The first petition (G.R. No. L-29471) questioned orders issued by Judge Salvador on August 29, September 3, and September 5, 1968, which enjoined strikes, picketing, and directed striking employees to return to work. The second petition (G.R. No. L-29487) challenged a September 6, 1968 resolution by the CIR en banc that dismissed PAFLU's motion for reconsideration of the August 29, 1968 order. 3. The Petition: PAFLU contended that the CIR and Judge Salvador lacked jurisdiction to issue the challenged orders because there was no new presidential certification of a labor dispute. They argued that the SSS's petition on August 29, 1968, seeking an interpretation of the collective bargaining agreement, was beyond the court's competence without such certification. PAFLU sought to have these orders declared null and void. The Supreme Court, however, found the SSS's contention persuasive, holding that a prior presidential certification and the ongoing effectivity of the award granted the CIR jurisdiction to interpret and enforce its terms.
Issue(s)
Whether the Court of Industrial Relations (CIR) had jurisdiction to issue orders concerning a collective bargaining agreement (CBA) adopted as an award, based on a prior presidential certification, despite the absence of a new presidential certification for the subsequent dispute regarding the interpretation of the CBA. Whether parties are justified in disobeying court orders, even if they believe the court acted without jurisdiction, when a remedy through appeal exists.
Ruling
The petitions are dismissed. The jurisdiction of respondent Judge Salvador and the CIR en banc is sustained. The Court also expressed emphatic disapproval of petitioner Union's conduct in failing to obey the orders.
Ratio Decidendi
On the jurisdiction of the CIR: The Court held that the CIR had jurisdiction. A presidential certification in 1963, which resulted in an award in 1966 embodying a collective bargaining agreement, was sufficient to vest jurisdiction in the CIR to act on a petition filed in 1968 seeking an interpretation of the CBA. The Court cited Sections 17 and 18 of Commonwealth Act No. 103 (the Court of Industrial Relations Act). Section 17 grants the CIR the power, during the effectiveness of an award, to alter, modify, or set aside any award, order, or decision, or reopen any question involved therein, after due hearing and upon application of an interested party. Section 18 empowers the CIR to determine the meaning or interpretation of any award, order, or decision upon petition by an interested party. The Court emphasized that the competence of the CIR lasts as long as the period specified in the award, which in this case was until June 30, 1969. The Court reiterated its consistent interpretation of these provisions as granting broad and continuing control over cases to the CIR to accord substantial justice, citing precedents like Goseco v. Court of Industrial Relations and Church v. La Union Labor Union. On the obligation to obey court orders: The Court strongly disapproved of petitioner Union's failure to abide by the orders, even under the assumption that the CIR acted without jurisdiction. The Court stated that no one may be permitted to take the law into his own hands or be the judge of the validity of court orders. Disobedience to court orders, even if susceptible to doubts on jurisdictional grounds, must be avoided, and the proper recourse is to seek reconsideration or appeal to a higher tribunal. The Court quoted Gompers v. Buck's Stove & Range Company to the effect that if parties could disobey orders based on their own judgment of validity, courts would be rendered impotent. The Court stressed that the rule of law requires obedience to judicial and quasi-judicial pronouncements as long as they stand unmodified, as this is essential for maintaining order and preventing a descent into rule by brute force. The Court acknowledged that while labor rights are protected, such protection does not extend to conduct at war with the fundamental postulate of the rule of law.
Main Doctrine
A presidential certification, even if made in 1963, resulting in an award in 1966 that embodies a collective bargaining agreement, vests jurisdiction in the Court of Industrial Relations to act on petitions concerning the interpretation or modification of such award during its effectivity period, even without a new presidential certification. Furthermore, parties are bound to obey court orders, even if they entertain doubts about the court's jurisdiction, as the remedy for such doubts lies in appeal, not disobedience.