DBP Employees Union-NATU v. Perez
REITERATIONFacts
The Antecedents: The Development Bank of the Philippines (DBP) filed Civil Case No. 54374 against the DBP Employees Union-NATU (DBPEU-NATU), its president Delia P. Medina, and the National Trade Union (NATU). The DBP sought to enjoin the union from staging a labor strike. The union and DBP had entered into a Collective Bargaining Agreement (CBA) on December 29, 1961, which included a provision where the union renounced strikes and other non-peaceful measures. Subsequently, on January 15, 1963, they entered into another agreement where DBP would seek a controlling opinion from the Secretary of Justice regarding whether DBP performed governmental or proprietary functions. The Secretary of Justice, in Opinion No. 41, Series of 1963, ruled that DBP performed governmental functions. Despite these agreements and the Secretary of Justice's opinion, the union announced and threatened to go on strike. Procedural History: The Court of First Instance of Manila issued a writ of preliminary injunction ordering the defendants to refrain from staging the strike. The court later rendered a judgment ordering the DBPEU to pay DBP P13,978.38 for actual damages from a July 2, 1963 strike and P131,589.30 for losses during an eleven-day strike from March 4 to March 14, 1964. The court also enjoined the DBPEU from violating its agreements not to resort to strikes. The complaint against Medina, Rodolfo Paet, and NATU was dismissed. The resolution on a contempt motion was held in abeyance pending the Supreme Court's resolution. The Petition: Two remedies were filed: G.R. No. L-22584, a petition for certiorari and prohibition assailing the writ of preliminary injunction for alleged lack of jurisdiction of the trial court over the labor dispute and the injunction itself. G.R. No. L-23083 is an appeal by the defendants from the final judgment of the trial court.
Issue(s)
Whether the Court of First Instance had jurisdiction over a labor dispute involving an alleged breach of a collective bargaining agreement and the staging of a strike. Whether the petition for certiorari and prohibition in G.R. No. L-22584, seeking to nullify a writ of preliminary injunction, had become moot and academic.
Ruling
In G.R. No. L-22584, the petition is dismissed for being moot and academic. In G.R. No. L-23083, the decision of the trial court in Civil Case No. 54374 is set aside for want of jurisdiction, and all complaints therein are dismissed.
Ratio Decidendi
On the issue of jurisdiction (G.R. No. L-23083): The Supreme Court held that the Court of First Instance acted without jurisdiction in taking cognizance of Civil Case No. 54374. The allegations in the complaint, even if taken at face value, described a labor dispute involving an alleged violation of a collective bargaining agreement and the threat of a strike. Such matters, particularly those involving unfair labor practices, fall under the exclusive jurisdiction of the Court of Industrial Relations (CIR) as provided by the Industrial Peace Act (Republic Act No. 875). The Court emphasized that the nature of the dispute, as pleaded, clearly indicated it was a labor dispute, not merely an action for enforcement of a contract. The Court reiterated its unwavering adherence to the principle that unfair labor practice cases are within the exclusive competence of the CIR, citing numerous previous decisions. The Court further clarified that collective bargaining is a continuous process, and failure to comply with the terms of a collective bargaining agreement constitutes an unfair labor practice. Therefore, the complaint, including the claim for damages, should have been filed with the CIR. The lack of jurisdiction of the trial court extended to all aspects of the case, including the issuance of injunctive relief and the award of damages. On the mootness of the petition (G.R. No. L-22584): The Supreme Court found that the petition for certiorari and prohibition in G.R. No. L-22584 had become moot and academic. The sole purpose of this petition was to stop the enforcement of a writ of preliminary injunction that enjoined the staging of a strike. Since the strike in question had already ended with a return-to-work agreement, the injunction had lost its purpose and effectivity. The Court cited its ruling in Progressive Labor Association vs. Villasor and Meralco Workers Union vs. Yatco, stating that there was no necessity in further declaring void and ineffective what was already ineffective by its nature. Therefore, the petition was dismissed on this ground.
Main Doctrine
A regular court, including a Court of First Instance, acts without jurisdiction in cases involving unfair labor practices, which fall under the exclusive jurisdiction of the Court of Industrial Relations. This lack of jurisdiction extends to all aspects of the case, including claims for damages and the issuance of injunctive relief.