National Federation of Labor v. Eisma
REITERATIONFacts
The Antecedents: Petitioners National Federation of Labor and Zambowood Monthly Employees Union filed a petition for direct certification as the sole exclusive collective bargaining representative for monthly paid employees of respondent Zamboanga Wood Products, Inc. Subsequently, the employees charged the company with underpayment of living allowances. The union then filed a notice of strike, citing illegal termination of its president, unfair labor practice, and employment of oppressive alien management personnel. A strike commenced on May 23, 1982. Procedural History: On July 9, 1982, Zamboanga Wood Products filed a complaint with respondent Judge Carlito A. Eisma for damages due to obstruction of private property, seeking a preliminary injunction and/or restraining order. Petitioners moved to dismiss, arguing that the acts complained of were incidents of picketing and thus fell under the exclusive jurisdiction of the Labor Arbiter pursuant to Batas Pambansa Blg. 227. Respondent Judge denied the motion to dismiss, leading to the filing of this certiorari and prohibition proceeding. The Petition: Petitioners sought to nullify the order of respondent Judge denying their motion to dismiss and to prohibit him from proceeding with the case, asserting that the court of first instance lacked jurisdiction over the subject matter.
Issue(s)
Whether the Court of First Instance (now Regional Trial Court) has jurisdiction over a suit for damages arising from picketing during a strike. Whether the acts complained of, which involved obstruction of ingress and egress to the employer's premises, fall within the exclusive jurisdiction of the Labor Arbiter.
Ruling
The writ of certiorari is granted, and the order of July 20, 1982, issued by respondent Judge is nullified and set aside. The writ of prohibition is likewise granted, enjoining respondent Judge from taking further action on Civil Case No. 716 (2751), except for the purpose of dismissing it. The temporary restraining order of August 5, 1982, is made permanent.
Ratio Decidendi
On the jurisdiction of the Court of First Instance over damages arising from picketing during a strike: The Court held that the Court of First Instance (now Regional Trial Court) was devoid of jurisdiction to entertain the suit for damages filed by Zamboanga Wood Products. The acts complained of, which involved the obstruction of ingress to and egress from the employer's facilities and its right of way, were incidents of picketing that accompanied a strike. Such matters fall squarely within the exclusive original jurisdiction of Labor Arbiters as provided for in Article 217 of the Labor Code, as amended by Presidential Decree No. 1691 and Batas Pambansa Blg. 130. The Court emphasized that jurisdiction is conferred by law and must be exercised within the bounds of that law. Any deviation from the statutory grant of jurisdiction cannot be tolerated, as consistently ruled by the Supreme Court. On whether the acts complained of fall within the exclusive jurisdiction of the Labor Arbiter: The Court affirmed that the exclusive original jurisdiction of a labor arbiter explicitly covers claims for damages arising from employer-employee relations, including those related to strikes and picketing. Presidential Decree No. 1691, which amended Article 217 of the Labor Code, restored the original jurisdiction of labor arbiters to hear and decide "All other claims arising from employer-employee relations, unless expressly excluded by this Code." Batas Pambansa Blg. 130 further amended Article 217, reinforcing the jurisdiction of labor arbiters over "wages, hours of work and other terms and conditions of employment." The Court cited previous rulings in Pepsi-Cola Bottling Co. v. Martinez, Ebon v. De Guzman, and Aguda v. Vallejos, which categorically held that labor arbiters have exclusive jurisdiction over such cases. Therefore, the respondent Judge acted beyond the scope of his authority when he entertained the suit for damages.
Main Doctrine
A court of first instance (now Regional Trial Court) is devoid of jurisdiction to entertain a suit for damages arising from picketing that accompanied a strike, as such claims fall under the exclusive original jurisdiction of Labor Arbiters.