Liwayway Publications, Inc. v. Permanent Concrete Workers Union
REITERATIONFacts
The Antecedents: Liwayway Publications, Inc. (appellee) leased a portion of premises from Permanent Concrete Products, Inc. (PCPI). Appellee had a bodega for newsprint within its sublet property, separate from PCPI's compound. On September 10, 1964, employees of PCPI, members of the Permanent Concrete Workers Union (appellants), declared a strike against PCPI. On October 3, 1964, the union picketed and prevented appellee's truck from entering the compound to load newsprint, intimidating appellee's employees. On October 6, 1964, union members again stopped appellee's general manager, personnel manager, bodega-in-charge, and other employees from accessing their newsprint bodega. Appellee repeatedly demanded the union cease these actions, but they refused. Consequently, appellee incurred expenses for renting another bodega and transporting newsprint. Procedural History: Appellee filed an action in the Court of First Instance (CFI) of Manila for a writ of preliminary injunction and damages. The CFI issued a writ of preliminary injunction on December 14, 1964, enjoining the defendants from threatening and intimidating appellee's officers and employees, blockading or picketing appellee's compound and gate, and interfering with appellee's passage to its bodega. The defendants moved to dismiss, arguing lack of jurisdiction (labor dispute falling under the Court of Industrial Relations - CIR) and that appellee was not the real party in interest. The CFI denied the motion to dismiss and to dissolve the injunction. Subsequently, the CFI declared the defendants in default and rendered a decision on February 16, 1965, making the injunction permanent and ordering defendants to pay appellee P10,152.42 plus interest, P1,000.00 as attorney's fees, and costs. Appellants appealed. The Petition: Appellants appealed the decision of the CFI, raising the sole issue of whether the lower court had jurisdiction to issue the injunction given the existence of a labor dispute.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue a writ of preliminary injunction in a case involving a labor dispute. Whether the acts complained of constitute a labor dispute over which the Court of Industrial Relations has exclusive jurisdiction. Whether the appellee is an 'innocent bystander' entitled to protection from the regular courts. Whether the complaint states a cause of action against the appellants.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance in toto, holding that the lower court had jurisdiction to issue the injunction and that the appellants are liable for damages.
Ratio Decidendi
On the jurisdiction of the Court of First Instance: The Court held that the primary issue is whether the case involves a labor dispute. If it does not, the Rules of Court govern the issuance of injunctions. The Court found that the appellee, Liwayway Publications, Inc., was an 'innocent bystander' with no connection to the labor dispute between the striking union and its employer, Permanent Concrete Products, Inc. The acts of picketing and preventing appellee's truck from accessing its newsprint bodega, and preventing appellee's employees from reaching it, were deemed mere acts of trespass. The Court emphasized that while the right to peaceful picketing is a constitutional right, it is not absolute and can be regulated by courts at the instance of third parties or 'innocent bystanders' whose rights are invaded. The Court distinguished this case from those where the CIR has exclusive jurisdiction, as the appellee's business and the dispute were unrelated. On whether the acts constitute a labor dispute: The Court determined that the acts complained of did not constitute a labor dispute in which the CIR would have exclusive jurisdiction. The appellee's business of publishing magazines was entirely unrelated to the cause of the strike by the union against its employer, PCPI. The fact that both entities were located in the same premises was not sufficient to establish an interwoven connection with the labor dispute. Therefore, the appellee was not part of the labor dispute and was entitled to seek protection from the regular courts. On the appellee as an 'innocent bystander': The Court applied the principle that third parties or 'innocent bystanders' with no industrial connection or interest in a labor dispute are entitled to protection from the courts. The picketing and obstruction by the union members directly affected the appellee's business operations by preventing access to essential newsprint. The Court cited Phil. Association of Free Labor Unions (PAFLU) vs. Judge Gaudencio Cloribel et al. to support the idea that courts can regulate picketing to insulate establishments or persons with no industrial connection to the dispute. On the cause of action and trespass: The Court rejected the appellants' contention that the appellee had no cause of action and should have sued its lessor, Don Ramon Roces, under Article 1654 of the Civil Code. Instead, the Court held that the acts of the union members were mere acts of trespass (perturbacion de mero hecho). Following the doctrine in Goldstein vs. Roces, the lessee has a direct action against the trespasser, and the lessor is not obliged to answer for mere acts of trespass by a third person. Article 1664 of the Civil Code was cited, which states that the lessee shall have a direct action against the intruder when the third person claims no right whatsoever. The Court clarified that the lessor's obligation under Article 1654 arises only in cases of legal trespass (perturbacion de derecho), not simple trespass.
Main Doctrine
A regular court has jurisdiction to issue an injunction to protect a third party or 'innocent bystander' from the effects of a labor dispute, even if the picketing is peaceful, when such third party has no industrial connection or interest foreign to the dispute, and the acts complained of constitute mere trespass.