Antipolo Highway Lines Employees Union v. De Jesus
REITERATIONFacts
The Antecedents: Private respondent Francisco DE JESUS, owner-operator of Antipolo Highway Lines (AHL), was informed by the Antipolo Highway Lines Employees' Union (AHLEU-KILUSAN), a duly registered union, of its organization and requested a conference for a Collective Bargaining Agreement (CBA). No action was taken by AHL. AHLEU-KILUSAN filed a Notice of Strike for unfair labor practices, including refusal to bargain and discrimination. A strike was declared and picketing ensued, but was lifted after conciliation. A 'Return to Work Agreement' was discussed but DE JESUS did not attend the subsequent conference. Instead, AHL entered into a CBA with another union, AHLEA-PTGWO. AHLEU-KILUSAN resumed picketing. Procedural History: On October 16, 1969, DE JESUS filed a Complaint for Damages with Preliminary Injunction against AHLEU-KILUSAN and its officers (petitioners) before the Court of First Instance (CFI) of Rizal. The complaint alleged that petitioners were not employees, called an illegal strike, prevented employees from working through threats and intimidation, and caused DE JESUS material loss. An ex-parte Restraining Order was issued the same day. Petitioners filed a Motion to Lift Restraining Order and/or Dismiss Complaint. On December 8, 1969, the CFI issued a Writ of Preliminary Injunction. On January 10, 1970, petitioners were declared in default. On January 23, 1970, the CFI rendered a Decision making the injunction permanent and ordering petitioners to pay damages and attorney's fees. Petitioners' Motion to Set Aside Decision and Order of Default was denied. The Petition: Petitioners filed a Petition for Certiorari, assailing the jurisdiction of the respondent Judge in taking cognizance of the case, issuing the restraining order and writ of preliminary injunction, and promulgating the decision. They contended that jurisdiction properly belonged to the Court of Industrial Relations (CIR) as the suit was interrelated with acts of unfair labor practice and constituted a labor dispute.
Issue(s)
Whether the respondent Judge acted without jurisdiction in issuing the restraining orders and writ of preliminary injunction. Whether the respondent Judge acted without jurisdiction in entertaining and taking cognizance of the Complaint for Damages with Preliminary Injunction. Whether the respondent Judge acted without jurisdiction in ultimately promulgating the Decision.
Ruling
The questioned Decision of January 23, 1970, and the orders of October 16, 1969 and December 8, 1969, issued by respondent Judge in Civil Case No. 12384, are declared null and void for want of jurisdiction and are accordingly set aside. Costs against private respondent.
Ratio Decidendi
On the issue of jurisdiction over the subject matter: The Supreme Court held that the Court of Industrial Relations (CIR) has exclusive jurisdiction over cases involving unfair labor practices, as provided by Section 5(a) of Republic Act No. 875 (Industrial Peace Act). The respondent Court of First Instance (CFI) acted without jurisdiction in taking cognizance of Civil Case No. 12384, which was essentially a labor dispute arising from alleged unfair labor practices, specifically the refusal of AHL to bargain collectively with AHLEU-KILUSAN. The Court emphasized that even if the suit was framed as one for damages with preliminary injunction, the underlying cause of action was intertwined with an alleged unfair labor practice, thus falling exclusively under the CIR's domain. The claim for damages did not divest the CIR of its jurisdiction, as the legality of the strike and the right to damages would depend on the outcome of the unfair labor practice case. The Court reiterated the principle that split jurisdiction is obnoxious to the orderly administration of justice. On the issuance of injunctive writs: Since the respondent Court of First Instance lacked jurisdiction over the subject matter, it also lacked the authority to issue ancillary writs of preliminary injunction. Furthermore, even if it had jurisdiction, the Court found that the procedure laid down by law for the issuance of injunctions in labor disputes, specifically Section 9(d) of Republic Act No. 875, was not followed. The restraining order was issued ex parte and continued in effect beyond the five-day limit prescribed by law, which is contrary to the procedure required for labor disputes. The Court cited Philippine Association of Free Labor Unions (PAFLU), et al. vs. Tan, et al. to underscore that injunctions in labor disputes cannot be granted ex parte and require a hearing with opportunity for cross-examination. On the employer-employee relationship and refusal to bargain: The Court stated that the issue of whether the petitioners were employees of DE JESUS was a matter of defense that could be properly raised in the Court of Industrial Relations. The mere allegation of the lack of an employer-employee relationship by DE JESUS in his complaint did not divest the CIR of its exclusive jurisdiction over the labor dispute. The fact that AHLEU-KILUSAN had already filed an Unfair Labor Practice charge with the CIR further solidified the exclusive jurisdiction of that court. The Court also noted that the respondent Judge overlooked Section 9(d) of the Industrial Peace Act regarding the duration of restraining orders, as the order issued on October 16, 1969, remained in effect until December 8, 1969, far exceeding the five-day statutory limit.
Main Doctrine
The Court of Industrial Relations has exclusive jurisdiction over cases involving unfair labor practices, and Courts of First Instance are without jurisdiction to issue injunctive writs in such matters, even if damages are claimed, as such claims are interwoven with the labor dispute.