Flores v. Filipino Hand Embroidery Co., Inc.
REITERATIONFacts
The Antecedents: Petitioners, factory workers of Filipino Hand Embroidery Co., Inc. (private respondent), organized the Hand Embroidery Workers Union-CCLU. They sent proposals for collective bargaining, which were refused. Private respondent claimed an existing contract with another union, the Filipino Hand Embroidery United Workers Organization (FUWC). Subsequently, 10% of employees filed a Petition for Certification Election with the Court of Industrial Relations (CIR). Private respondent then dismissed 43 workers, including petitioners, allegedly for failing to meet production quotas. Petitioners' union filed a charge of unfair labor practice with the CIR. Procedural History: On the same day the unfair labor practice charge was filed, private respondent filed a civil case for damages with the Court of First Instance (CFI) of Rizal, seeking an injunction against petitioners for allegedly threatening to cordon the premises. The CFI judge issued a restraining order. Petitioners moved to lift the injunction and dismiss the case for lack of jurisdiction, which was denied. Their motion for reconsideration was also denied. The CFI judge later declared petitioners in default and allowed private respondent to present evidence ex-parte. The Petition: Petitioners filed a petition for certiorari and prohibition with the Supreme Court, seeking to restrain the CFI judge from proceeding with the civil case due to alleged lack of jurisdiction.
Issue(s)
Whether the respondent judge erred in maintaining his jurisdiction over Civil Case No. 14747. Whether the regular courts have jurisdiction over complaints for damages arising from or intertwined with unfair labor practice.
Ruling
The petition is impressed with merit. The acts, orders, and decisions of the respondent judge are declared void ab initio, and the issued writ of preliminary injunction is made permanent.
Ratio Decidendi
On whether the respondent judge erred in maintaining his jurisdiction over Civil Case No. 14747: The Supreme Court ruled that the respondent judge erred in maintaining jurisdiction. The Court found that private respondent's action for damages arose out of, or was connected or intertwined with, the unfair labor practice case filed with the Court of Industrial Relations (CIR). It is settled jurisprudence that where a plaintiff's cause of action for damages is intertwined with alleged unfair labor practices, jurisdiction properly belongs to the CIR. The Court cited Maria Cristina Fertilizer Plant Employees Asso. vs. Tandayag (83 SCRA 57 [1978]) to support this principle. The respondent judge's awareness of the pending certification election and unfair labor practice charge in the CIR was sufficient reason to question his jurisdiction. The Court reiterated that all matters involved in proceedings for certification election and unfair labor practice pending in the CIR are within its exclusive jurisdiction, and a Court of First Instance has no jurisdiction to issue injunctions related to such matters, citing National Mines and Allied Workers' Union vs. Ilao (7 SCRA 113 [1963]). On whether the regular courts have jurisdiction over complaints for damages arising from or intertwined with unfair labor practices: The Supreme Court held that regular courts do not have jurisdiction over such complaints. Citing PLDT Company vs. Free Telephone Workers Union (116 SCRA 145 [1982]) and Holganza vs. Apostol (76 SCRA 191 [1977]), the Court stated that jurisprudence under R.A. 875 established that jurisdiction over such damages complaints was exclusively lodged with the defunct Court of Industrial Relations. The assumption and exercise of jurisdiction by regular courts over the same is a nullity. The Court emphasized that allowing regular courts to pass upon such demands would sanction split jurisdiction, which is prejudicial to the orderly administration of justice. Therefore, the respondent judge's declaration that petitioners were dismissed for cause, made without jurisdiction, is a nullity.
Main Doctrine
A regular court (Court of First Instance) has no jurisdiction over complaints for damages that arose out of, or are necessarily intertwined with, alleged unfair labor practices committed by a union, as such jurisdiction is exclusively lodged with the Court of Industrial Relations.