Hawaiian-Philippine Company v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a strike staged by the respondent Congress of Independent Organizations-ALU (CIO) on April 19, 1968, against petitioner Hawaiian-Philippine Company. The strike was precipitated by the company's alleged refusal to recognize and negotiate with the CIO as the exclusive bargaining agent for its workers, despite a Collective Bargaining Agreement, and its refusal to honor the terms of that agreement. This led to prior unfair labor practice complaints filed by the union against the company. 2. Procedural History: Hawaiian-Philippine Company filed a petition with the Court of Industrial Relations (CIR) seeking to declare the strike illegal and requesting a temporary restraining order to prevent the union from blocking ingress and egress to the company premises. The trial judge issued an order on May 10, 1968, partially restraining the union, and subsequently, on July 12, 1968, issued a preliminary injunction enjoining the union from picketing the company's entrances, requiring the company to post a P5,000.00 bond. The respondent union moved for reconsideration, and the CIR en banc, in a resolution dated May 26, 1969, vacated the trial judge's orders, ruling that injunctions in labor disputes must strictly follow Republic Act 875 and that the orders were void for procedural defects. 3. The Petition: This petition for review was filed with the Supreme Court by Hawaiian-Philippine Company, challenging the CIR en banc's resolution that vacated the restraining orders. The company sought to reverse the CIR's decision, arguing that the acts sought to be enjoined involved force and violence, thus falling outside the strictures of R.A. 875, and that the trial judge correctly issued the restraining order. The Supreme Court issued a preliminary injunction on September 19, 1969, restraining the CIR from giving effect to its resolution. The issues before the Supreme Court were whether a labor dispute existed and whether the trial judge correctly issued the restraining order under Rule 58 of the Rules of Court.
Issue(s)
Whether or not a labor dispute existed between the petitioner and the respondent union. Whether or not the trial judge correctly issued the restraining order on the basis of Rule 58 of the Rules of Court.
Ruling
The petition is denied, and the writ of preliminary injunction issued on September 19, 1969, is dissolved. The resolution of the Court of Industrial Relations en banc vacating the trial judge's orders is sustained.
Ratio Decidendi
On the existence of a labor dispute: The Court found the trial judge's view that no labor dispute existed to be untenable. It noted that prior to the CIR case, two unfair labor practice complaints had been filed by the respondent union against the petitioner for refusal to recognize and negotiate with the union as the bargaining agent and for management's refusal to respect the Collective Bargaining Agreement. These actions led to the strike, thus establishing that the strike arose from and was part of a labor dispute. The Court emphasized that a labor dispute, as defined in Section 20 of Republic Act No. 875, includes controversies concerning representation in negotiating terms of employment, which was clearly the situation. On the issuance of the restraining order: The Court affirmed the respondent union's assertion that the trial judge's orders were unlawful and improper. The issuance of injunctions in cases involving labor disputes is strictly governed by Section 9(d) of Republic Act No. 875. This section mandates a hearing with testimony of witnesses in open court, opportunity for cross-examination, and findings of fact before an injunction can be issued. While a temporary restraining order may be issued without notice if irreparable injury is alleged and testimony under oath supports it, such an order must be effective for no longer than five days. Furthermore, the law requires the complainant to first file an undertaking with adequate security to compensate for any loss or damage caused by the improvident issuance of the order. The trial judge's orders failed to comply with these mandatory requirements, rendering them void.
Main Doctrine
The provisions of Republic Act No. 875, particularly Section 9(d) concerning injunctions in labor disputes, must be strictly followed, requiring a hearing, notice, and posting of a bond, unless a temporary restraining order is issued without notice due to imminent and irreparable injury, which must be effective for no more than five days.