National Mines & Allied Workers' Union v. Valero
REITERATIONFacts
The Antecedents: Private respondent, Camarines Norte Mahogany Co., Inc., engaged in exporting logs, stocked its logs at a pond in Mercedes, Daet, Camarines Norte. Petitioner, National Mines & Allied Workers' Union (NAMAWUMIF), with a local branch, requested recognition as the exclusive bargaining representative for stevedores and preference for its members in loading logs. Private respondent rejected this, having authorized Mercedes Arrastre to load its logs. Subsequently, petitioner entered into an agreement with Philippine Island Arrastre, an alleged contractor of private respondent, recognizing petitioner as the sole bargaining representative. When the vessel "Dai Leung" arrived to load logs, petitioner filed a notice of strike and prevented loading. Procedural History: Private respondent filed a complaint for injunction with the Court of First Instance (CFI) of Camarines Norte, alleging no relation with petitioner and significant daily losses due to demurrage. The CFI issued a writ of preliminary injunction restraining petitioner from preventing the loading. Petitioner moved for reconsideration and dismissal, arguing the writ was issued without hearing and that the case falls under the jurisdiction of the Court of Industrial Relations (CIR) due to an alleged unfair labor practice. The CFI denied the motion, modified the injunction to cover any vessel, and declared petitioner in default for failure to file an answer. The Petition: Petitioner filed a petition for certiorari and prohibition with the Supreme Court, seeking to annul the CFI's orders, questioning the jurisdiction of the CFI and the propriety of the injunction's issuance.
Issue(s)
Whether respondent Judge acted without or in excess of jurisdiction in issuing the questioned orders regarding the writ of preliminary injunction. Whether the former Court of First Instance or the defunct Court of Industrial Relations has jurisdiction over the case, considering the alleged employer-employee relationship and labor dispute.
Ruling
The petition is dismissed. The Court of First Instance had jurisdiction to issue the questioned orders.
Ratio Decidendi
On the propriety of the writ of preliminary injunction: The Court held that the writ of preliminary injunction dated June 3, 1970, was not improvidently issued. While the general rule requires notice and hearing, Section 5 of Rule 58 of the Rules of Court allows for ex parte issuance when great or irreparable injury would result before the matter can be heard. The verified complaint sufficiently alleged that petitioner, allegedly unconnected with respondent, illegally prevented log loading, causing significant daily losses of $800.00 (P4,800.00) in demurrage. The posting of a P3,000.00 bond further mitigated potential damages to petitioner. Petitioner was not denied due process as it was able to present its arguments in its motion for reconsideration and supplemental motion. On the jurisdiction of the court: The Court reiterated that for the Court of Industrial Relations (CIR) to acquire jurisdiction under Republic Act No. 875, there must be an employer-employee relationship, or the claimant must seek reinstatement, and the controversy must relate to specific labor law matters or be certified as involving national interest. The Court found that the allegations in the complaint filed before the CFI expressly negated any employer-employee relationship between the parties, stating that private respondent had no connection with petitioner and had not availed itself of the union's services. These allegations, which clearly indicated the absence of an employer-employee relationship, vested the CFI with the authority to assume jurisdiction. The mere allegations by petitioner in its motion for reconsideration regarding a labor dispute and a contractor's agreement did not automatically divest the CFI of its jurisdiction, as these matters needed to be threshed out during trial. Private respondent's denial of authorizing the contractor to enter into such an agreement further supported the CFI's jurisdiction.
Main Doctrine
A Court of First Instance has jurisdiction over a case seeking an injunction to restrain picketing and obstruction of log loading operations, even if the union claims a labor dispute exists, if the complaint filed before it negates the existence of an employer-employee relationship, which is a prerequisite for the Court of Industrial Relations to acquire jurisdiction under Republic Act No. 875.