Philippine Appliance Corporation Employees Association-NATU v. Philippine Appliance Corporation
REITERATIONFacts
The Antecedents: Petitioner union filed a notice of strike against private respondent due to alleged unfair labor practices. Despite evidence of majority membership, the union was refused recognition, leading to a strike on January 16, 1971. On February 2, 1971, private respondent filed a complaint with the Court of First Instance of Rizal seeking an injunction against picketing. Procedural History: On February 4, 1971, the respondent Judge issued an ex-parte restraining order against petitioners without complying with the Industrial Peace Act. Petitioners' motion to dismiss and dissolve the restraining order was denied. On May 7, 1971, the respondent Judge issued a writ of preliminary injunction, conditioned upon a bond, prohibiting petitioners from picketing. The Petition: Petitioners filed a suit for certiorari and prohibition, assailing the jurisdiction of the respondent Judge for entertaining an unfair labor practice case exclusively cognizable by the Court of Industrial Relations.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue a restraining order and preliminary injunction in a case involving alleged unfair labor practices. Whether the orders issued by the respondent Judge are null and void for lack of jurisdiction.
Ruling
The writ of certiorari is granted, and the orders of the respondent Judge dated February 4, 1971, and May 7, 1971, are nullified, set aside, and declared to be of no force and effect. The writ of prohibition is also granted, ordering the dismissal of the complaint in Civil Case No. 14344. The restraining order issued by this Court is declared permanent. Costs are against the private respondent.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated the doctrine of sole and exclusive competence of the labor tribunal (then the Court of Industrial Relations) over unfair labor practice cases. The Court emphasized that jurisdiction is conferred by law and must be beyond doubt. The private respondent's assertion that the lack of jurisdiction was "not patent or clearly illegal" was deemed insufficient, as jurisdiction is never presumed. The Court found it inexplicable why the private respondent resorted to ordinary courts when the matter of certification of the collective bargaining agency was with the appropriate tribunal. The respondent Judge was therefore devoid of jurisdiction to issue the restraining order and preliminary injunction. On the nullity of the orders: Since the respondent Judge acted without or in excess of his jurisdiction, the orders he issued, namely the restraining order of February 4, 1971, and the preliminary injunction of May 7, 1971, are null and void and have no force and effect. The Court's power to issue a writ of certiorari is invoked to correct grave abuse of discretion amounting to lack of jurisdiction. The failure to comply with the procedure and requirements of the Industrial Peace Act further underscored the illegality of the respondent Judge's actions. The Court also noted that the former Court of Industrial Relations has been replaced by the National Labor Relations Commission under the new Labor Code, indicating that such matters should be handled by the appropriate labor agencies.
Main Doctrine
Courts of First Instance are devoid of jurisdiction to entertain cases exclusively cognizable by the Court of Industrial Relations, such as unfair labor practice cases, and any order issued by them in such cases is null and void.