Cyphil Employees Association-NATU v. Pharmaceutical Industries Inc.
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a notice of strike filed by the Cyphil Employees Association-NATU (petitioner union) against Cyanamid Philippines, Inc. (and its sister firm, Pharmaceutical Industries, Inc., the respondent company) due to alleged unfair labor practices, including interference with the union's right to self-organization and refusal to bargain collectively. Despite conciliation efforts, the company allegedly continued these practices, compelling the union to declare a strike on March 25, 1971, and to establish peaceful picket lines. 2. Procedural History: On March 31, 1971, Pharmaceutical Industries, Inc. filed a complaint with the Court of First Instance of Manila, seeking an injunction with damages and a preliminary injunction. The respondent judge, Alberto J. Francisco, issued an ex parte restraining order without notice or hearing, prohibiting the petitioner union from picketing. The petitioner union filed a motion to dismiss, arguing that the case involved a labor dispute and unfair labor practices exclusively cognizable by the Court of Industrial Relations. However, the respondent judge denied this motion and issued a writ of preliminary injunction. 3. The Petition: The petitioner union filed a petition for certiorari with the Supreme Court, arguing that the respondent judge acted without or in excess of jurisdiction by entertaining a labor dispute that fell under the exclusive jurisdiction of the Court of Industrial Relations. The petitioner also contended that the restraining order prohibiting peaceful picketing was issued in disregard of established jurisprudence. The Supreme Court, referencing prior rulings on the exclusive jurisdiction of the Court of Industrial Relations in labor disputes and the unconstitutionality of prohibiting peaceful picketing, granted the writ of certiorari and made permanent the preliminary injunction issued by the Supreme Court, ordering the dismissal of the case before the Court of First Instance.
Issue(s)
Whether the Court of First Instance has jurisdiction over a labor dispute involving unfair labor practices. Whether the respondent Judge committed grave abuse of discretion amounting to lack of jurisdiction in issuing an ex parte restraining order and preliminary injunction in a labor dispute. Whether peaceful picketing can be prohibited.
Ruling
The writ of certiorari is granted. The respondent Judge was devoid of jurisdiction to entertain the civil case. The preliminary injunction issued by the Supreme Court is made permanent, and Civil Case No. 82752 of the Court of First Instance of Manila is ordered dismissed. Costs are against the private respondent.
Ratio Decidendi
On the jurisdiction of the Court of First Instance over labor disputes: The Supreme Court reiterated the well-established doctrine that labor disputes involving unfair labor practices are exclusively cognizable by the Court of Industrial Relations (CIR). The Court cited numerous precedents, including Associated Labor Union v. Gomez, Progressive Labor Association v. Atlas Consolidated Mining and Development Corporation, Leoquenio v. Canada Dry Bottling Co., and Associated Labor Union v. Cruz, all of which upheld the exclusive jurisdiction of the CIR to prevent the "obnoxious" and "prejudicial" "split jurisdiction" in the administration of justice. The respondent Judge, by entertaining the complaint for injunction with damages arising from alleged unfair labor practices, acted without or in excess of jurisdiction. On the issuance of an ex parte injunction: The respondent Judge's issuance of an ex parte restraining order without notice or hearing, and without observing the procedural requirements of Republic Act 875, in a labor dispute involving alleged unfair labor practices, constituted a grave abuse of discretion amounting to lack of jurisdiction. This action disregarded repeated pronouncements of the Supreme Court against the grant of ex parte injunctions and restraining orders, especially in labor disputes. The Court emphasized that such an act was a clear overreach of judicial power, as the matter fell squarely within the exclusive domain of the CIR. On the prohibition of peaceful picketing: The Supreme Court reaffirmed its ruling in Mortera v. Court of Industrial Relations that peaceful picketing cannot be prohibited. Peaceful picketing is an exercise of the freedom of speech guaranteed by the Constitution. Therefore, any order prohibiting peaceful picketing, especially when issued by a court lacking jurisdiction over the underlying labor dispute, is invalid and cannot be sustained. The prohibition of peaceful picketing was a secondary infirmity of the respondent Judge's order, but the primary issue of jurisdiction rendered the entire proceeding void.
Main Doctrine
The Court of First Instance lacks jurisdiction over labor disputes involving unfair labor practices, which are exclusively cognizable by the Court of Industrial Relations. Issuing an ex parte injunction in such cases constitutes grave abuse of discretion amounting to lack of jurisdiction. Peaceful picketing cannot be prohibited as it is a form of constitutionally guaranteed freedom of speech.