G.R. No. L-30030 & L-33801 November 29, 1971
PHILIPPINE PACKING CORPORATION and RICARTE ABEJUELA, petitioners, vs. HON. BALDOMERO B. REYES, Judge, Court of Agrarian Relations, 14th Regional District; NERIO MEDEL, ERIBERTO CABAÑEZ, MANUEL AJOC and PETRONIO ABRIO, respondents. PHILIPPINE PACKING CORPORATION, petitioner, vs. HON. BALDOMERO B. REYES and JESUS LUMDANG, respondents.

FACTS

These consolidated petitions involve the same legal issue. In G.R. No. L-30030, respondent agricultural workers filed a complaint in 1965 with the Court of Agrarian Relations (CAR) for dismissal without justifiable cause, deemed an unfair labor practice charge, alleging they were dismissed for refusing to join a company-favored union. In G.R. No. L-33801, a union president filed a similar unfair labor practice complaint in 1971, alleging dismissal due to union activities. In both cases, petitioner Philippine Packing Corporation moved to dismiss the complaints, arguing that the CAR did not validly acquire jurisdiction because no preliminary investigation was conducted as required by Section 5(b) of Republic Act No. 875 (The Industrial Peace Act) for unfair labor practice cases.
The respondent judge sustained the CAR’s jurisdiction, dismissing the petitioner’s contention. The court relied on this Court’s prior ruling in Matillano vs. De Leon, which held that neither the Rules of the Court of Agrarian Relations nor the Rules of Court required such a preliminary investigation for cases filed before the effectivity of the Agricultural Land Reform Code (RA 3844) on August 8, 1963. The petitioner, however, contends that by virtue of Section 47 of RA 3844, which applies laws for non-agricultural workers to farm workers where not inconsistent, the preliminary investigation requirement under RA 875 became applicable to agricultural workers and is a mandatory jurisdictional step for the CAR.

ISSUE

Whether a preliminary investigation, as required under Section 5(b) of Republic Act No. 875 for unfair labor practice cases filed with the Court of Industrial Relations, is a mandatory jurisdictional requirement for unfair labor practice cases filed with the Court of Agrarian Relations after the effectivity of the Agricultural Land Reform Code ( Republic Act No. 3844 ).

RULING

The Supreme Court ruled that a preliminary investigation is NOT a mandatory requirement for unfair labor practice cases filed with the Court of Agrarian Relations, even after the effectivity of RA 3844. The Court found the petitioner’s submission without merit. The rationale in Matillano remains applicable. The Court traced the procedural history, noting that the Court of Industrial Relations (CIR) originally had jurisdiction over both industrial and agricultural labor disputes. While RA 875 later imposed a preliminary investigation requirement for unfair labor practice cases filed with the CIR, the creation of the separate Court of Agrarian Relations (CAR) by Republic Act No. 1267 , and its subsequent governing law, Republic Act No. 3844 , provided its own distinct procedure.
Section 155 of RA 3844 explicitly states that the CAR and its Hearing Commissioners shall follow the rules of procedure and evidence prevailing in the courts of first instance, meaning the Rules of Court. The Court emphasized that the right to a preliminary investigation is statutory. Since RA 3844, which governs the CAR, did not incorporate or require the preliminary investigation procedure outlined in Section 5(b) of RA 875, such a step is not a jurisdictional prerequisite. Congress, in its wisdom, determined that the application of the Rules of Court provided sufficient safeguard against frivolous complaints. Therefore, the CAR validly acquired jurisdiction over the