Philippine Association of Free Labor Unions v. Court of First Instance of Rizal
REITERATIONFacts
The Antecedents: Petitioners, officers and/or members of the Philippine Association of Free Labor Unions (PAFLU) Luzano Faction and laborers of Philippine Blooming Mills Company, Inc., allegedly staged a strike by establishing picket lines in front of the factory, resulting in work stoppage and paralysis of operations. The information alleged that this was done willfully, unlawfully, and feloniously, to the damage and prejudice of the company. Procedural History: A motion to quash was filed before the Court of First Instance of Rizal on the ground of lack of jurisdiction, asserting that Presidential Decrees Nos. 823 and 849 precluded the fiscal from filing the information without exhausting jurisdictional requisites, especially since the labor dispute had been settled. The respondent court did not grant the motion. The Petition: Petitioners filed a certiorari and prohibition proceeding before the Supreme Court, questioning the jurisdiction of the respondent Court of First Instance to entertain the criminal suit. They argued that the National Labor Relations Commission (NLRC) had primary jurisdiction to determine the legality of the strike, and that the filing of the information was premature. The Supreme Court issued a temporary restraining order.
Issue(s)
Whether the Court of First Instance of Rizal has jurisdiction to entertain a criminal suit arising from an alleged illegal strike, and whether the filing of the information was premature considering the applicable Presidential Decrees and the pending labor dispute before the National Labor Relations Commission. Whether peaceful picketing is protected under freedom of expression. On the effect of Batas Pambansa Blg. 227 on the penal aspect of Presidential Decree No. 823, as amended, concerning the criminal action.
Ruling
The Supreme Court granted the writ of certiorari and prohibition, declared the proceedings in the criminal case null and void, and prohibited the respondent judge from acting on the case, except to dismiss it. The temporary restraining order was made permanent.
Ratio Decidendi
On the jurisdiction of the Court of First Instance and the prematurity of the information: The Court held that the Court of First Instance of Rizal lacked jurisdiction to entertain the criminal suit arising from the alleged illegal strike. This is because the determination of the legality or illegality of a strike, especially when involving a labor dispute, falls under the primary jurisdiction of the National Labor Relations Commission (NLRC) or the Secretary of Labor, as mandated by Presidential Decree Nos. 823 and 849. The Court emphasized that Presidential Decree No. 849, which amended Presidential Decree No. 823, recognized the right to strike under certain conditions, particularly concerning unresolved economic issues in collective bargaining, and allowed for strikes unless the dispute was certified to the NLRC for compulsory arbitration. The filing of the information on July 1, 1976, was deemed premature because the legality of the strike had not yet been determined by the appropriate labor authorities. The Court reiterated its consistent stance that labor tribunals are better equipped to handle labor controversies than regular courts. On the protection of peaceful picketing: The Court affirmed that peaceful picketing is embraced within the guarantee of freedom of expression, citing previous decisions such as Mortera v. Court of Industrial Relations and Associated Labor Union v. Gomez. The Court noted that Presidential Decree No. 849 accorded due recognition to the status of picketing. Furthermore, the Court pointed to Batas Pambansa Blg. 227, the prevailing law at the time of the decision, which explicitly prohibited acts of violence, coercion, intimidation, or obstruction during picketing, thereby reinforcing the protection afforded to peaceful picketing. The Court concluded that the information was limited to petitioners engaging in picketing, which, if peaceful, is constitutionally protected. On the effect of Batas Pambansa Blg. 227: The Court observed that Batas Pambansa Blg. 227, enacted after the alleged offense, further clarified the conduct permissible during picketing and repealed or modified inconsistent laws. Since the penal aspect of Presidential Decree No. 823, as amended, formed the basis for the criminal action, the Court implied that any offense committed under the previous decrees might no longer be punishable under the new law, reinforcing the grant of the petition.
Main Doctrine
The Court of First Instance lacks jurisdiction to entertain a criminal suit arising from an alleged illegal strike when the legality of the strike is a matter primarily cognizable by the National Labor Relations Commission, and the filing of the information was premature given the then-applicable labor laws which recognized the right to strike under certain conditions and protected peaceful picketing.