Silva Pipe Workers Union-National Association of Trade Unions v. Filipino Pipe & Foundry Corporation
REITERATIONFacts
The Antecedents: The Filipino Pipe & Foundry Corporation (Company) filed a civil case for damages with preliminary injunction against the Silva Pipe Workers Union-NATU (Union) before the Court of First Instance (CFI) of Rizal. The Company prayed for the Union to be enjoined from continuing a strike, to lift picket lines, to declare the strike illegal, and to hold the Union liable for damages. The CFI issued an ex-parte temporary restraining order (TRO) enjoining the Union from preventing ingress and egress, allowing free access of clients, removing roadblocks, and refraining from threatening bodily harm. Procedural History: The Union moved to dismiss the complaint, arguing that the case arose from an unfair labor practice (ULP) exclusively cognizable by the Court of Industrial Relations (CIR). The CFI denied the motion and required the Union to file an Answer. Subsequently, the Company filed a ULP complaint against the Union before the CIR. The CFI, upon motion of the Company, declared the Union in default for failure to file an Answer. The Union sought reconsideration, which was denied. The Petition: The Union filed a Petition for certiorari and Prohibition with Preliminary Injunction seeking to nullify all proceedings before the CFI.
Issue(s)
Whether the Court of First Instance (CFI) had jurisdiction to take cognizance of Civil Case No. 13150, a complaint for damages with preliminary injunction arising from a labor dispute involving alleged unfair labor practices. Whether the CFI had jurisdiction to issue a temporary restraining order in a case involving an unfair labor practice.
Ruling
The Petition is granted. The Temporary Restraining Order issued by the CFI of Rizal, Branch II, is declared null and void. All proceedings before it in Civil Case No. 13150 are set aside, and said Court is permanently enjoined from taking any further action on the case except to dismiss the same.
Ratio Decidendi
On the jurisdiction of the CFI over the labor dispute: The Supreme Court ruled that the CFI was bereft of jurisdiction to take cognizance of the case before it. The ULP complaint filed by the Company before the CIR unequivocally established that an unfair labor practice was involved, over which the CIR had sole and exclusive jurisdiction pursuant to Section 5(a) of the Industrial Peace Act (RA 875). The Company's cause of action in the civil case before the CFI arose out of, or was closely intertwined with, the unfair labor practice allegedly committed by the Union. The existence of such a controversy is sufficient to remove it from the competence of the regular courts and place it within the exclusive jurisdiction of the CIR. It was clarified that an unfair labor practice need not be committed by management alone; labor may also be guilty thereof, and the jurisdiction over such cases, whether on the part of management or a labor union, is vested with the CIR. The Court cited Security Bank Employees Union-NATU vs. Security Bank and Trust Company and Philippine Association of Free Labor Union (PAFLU) vs. De los Angeles. On the CFI's jurisdiction to issue a restraining order: The contention of the Company that the CFI had jurisdiction because the case was brought principally to prevent further commission of unlawful acts was not well-taken. The Court reiterated the ruling in National Garments and Textile Worker's Union-PAFLU, etc., vs. Hon. Hermogenes Caluag, et al., stating that even if the case involves acts of violence, intimidation, and coercion, if the issue is interwoven with an unfair labor case pending before the CIR, whose jurisdiction is exclusive, then it does not come under the jurisdiction of the trial court. Such acts of violence, intimidation, and coercion come within the purview of Section 9(d) of RA 875, which may be enjoined by the CIR. The Court emphasized that in a long line of decided cases, it has invariably held that the CIR has exclusive jurisdiction over labor disputes involving unfair labor practice, with the exclusive power to issue a temporary restraining order to enjoin acts in connection therewith. This exclusive jurisdiction is based on the principle that picketing and strikes may be mere incidents or consequences of an unfair labor practice, and thus, any injunction prayed for in connection with such a labor dispute should originate from the court having jurisdiction over the main case, as it is that court that has cognizance of all relevant facts. The Court cited PAFLU, et al. vs. Tan, Phil. Communications, Electronic and Electricity Workers Federation vs. Nolasco, National Garment and Textile Workers' Union vs. Hon. H. Caluag, and Erlanger and Galinger, Inc. vs. Erlanger and Galinger Employees Association - NATU.
Main Doctrine
The Court of First Instance is bereft of jurisdiction to take cognizance of a labor dispute involving unfair labor practice, as exclusive jurisdiction is vested with the Court of Industrial Relations.