Tiong San Employees Union v. Lao
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a strike staged by employees of Tiong San Bazaar on July 10, 1967. The employer, Andres Lao, Sr., alleged that the striking employees, affiliated with the Tiong San Employees Union and the Federation of Hotels, Restaurants and General Workers Union of the Philippines, engaged in illegal picketing, obstructing ingress and egress of customers and employees, and causing significant daily losses. 2. Procedural History: The employer initially sought an injunction from the Court of Industrial Relations (CIR) on July 18, 1967 (Case No. 219-Inj.), which was granted ex parte on July 25, 1967, and later affirmed by the CIR en banc on December 4, 1967. The unions moved to dismiss the injunction for lack of jurisdiction and non-compliance with requisites. Subsequently, the employer filed unfair labor practice charges against the unions and individuals on July 29 and August 3, 1967 (Cases Nos. 4799-ULP, 4736-ULP, and 4803-ULP). The CIR dismissed some of these charges, declared the strike illegal, and found certain dismissals justified. Separately, Andres Lao, Sr. filed a civil case for damages in the Court of First Instance of Manila (Civil Case No. 71186) on November 6, 1967, which the defendants sought to dismiss. The Court of First Instance denied the motion to dismiss, leading to a petition for prohibition filed in the Supreme Court. 3. The Petition: G.R. No. L-28389 is a petition for review of the CIR's injunction order and its en banc affirmation, questioning the validity of the ex parte injunction. G.R. No. L-29079 is an original petition for prohibition, arguing that the Court of First Instance of Manila lacked jurisdiction to hear the damages case, contending it should have been adjudicated within the unfair labor practice proceedings or that the case was premature due to pending appeals. The Supreme Court consolidated these cases, finding the appeal in L-28389 moot and academic due to the injunction's expiration and dismissing the prohibition petition in L-29079, holding that a claim for damages arising from illegal acts is a civil matter cognizable by regular courts, distinct from labor disputes.
Issue(s)
Whether the appeal from the CIR's ex-parte injunction order and its affirmation by the CIR en banc is moot and academic. Whether the Court of First Instance of Manila has jurisdiction to entertain the action for damages filed by Andres Lao, Sr. Whether the action for damages filed in the Court of First Instance is premature.
Ruling
The appeal in G.R. No. L-28389 is dismissed as moot and academic. The petition in G.R. No. L-29079 is dismissed. The Court of First Instance of Manila has jurisdiction over the action for damages.
Ratio Decidendi
On the mootness of the appeal in G.R. No. L-28389: The Supreme Court held that the ex-parte writ of preliminary injunction issued by the CIR on July 25, 1967, lost its efficacy five days thereafter, as provided by Section 9(d)(5) of Republic Act No. 875. This fact was admitted by the petitioners themselves. Therefore, even if the requisites for its issuance were not met, the question of its validity became moot and academic upon its expiration. Consequently, the CIR en banc's denial of the motion for reconsideration, which affirmed the moot injunction, could not be reviewed meaningfully. An appeal from such a resolution would also be moot and academic and serve no legitimate purpose. On the jurisdiction of the Court of First Instance in G.R. No. L-29079: The Court ruled that the action for damages filed by Andres Lao, Sr. in the CFI of Manila was a simple case for the recovery of damages arising from alleged illegal acts committed by the defendants. This action had nothing to do with the employer-employee relationship or any labor dispute pending in the CIR. The decision in the consolidated ULP cases (Nos. 4736-ULP, 4799-ULP, and 4803-ULP), which declared the strike illegal, had already become final. The jurisprudential rule at the time was that the CIR could not award damages sustained by an employer in an unfair labor practice case, as such an issue would be purely civil in nature, cognizable by the Court of First Instance. The pendency of an appeal from the CIR's injunction order did not divest the CFI of jurisdiction or render the damages action premature. On the prematurity of the action for damages: The Court found no merit in the contention that the damages case was premature. The decision in the consolidated ULP cases, which declared the strike illegal and formed the basis for the damages claim, had already become final. The issue raised in the motion for reconsideration before the CIR en banc concerning the injunction, besides being moot, did not pertain to the alleged commission of illegal acts by the defendants up to October 10, 1967, which were the basis for the damages claim. Therefore, the action for damages was properly filed and not premature, as it was based on a final determination of the illegality of the strike and picketing.
Main Doctrine
An ex-parte writ of preliminary injunction issued by the Court of Industrial Relations loses its efficacy after five days, rendering any appeal from its affirmation moot and academic. Actions for damages arising from illegal acts during a strike, where the illegality of the strike has been finally determined by the Court of Industrial Relations, are cognizable by the regular courts of general jurisdiction, not the Court of Industrial Relations, as they present purely civil claims.