G.R. No. L-26507 May 30, 1975
LAKAS NG MANGGAGAWANG MAKABAYAN (LMM), petitioner, vs. HON. WALFRIDO DELOS ANGELES, as Judge of the Court of First Instance of Rizal, Branch IV, Quezon City, VITSON MILLS, INC., and RUFA NAMBATAC, LEONIDA VALLEJOS, VICTORIA KONG, EDEN MAGDAONG and NENA LIBERTA, respondents.

FACTS

Petitioner Lakas Ng Manggagawang Makabayan (LMM) filed charges for unfair labor practice against respondent Vitson Mills, Inc. with the Court of Industrial Relations (CIR) on April 18, 1966. A strike ensued, leading to picketing. Subsequently, on July 1, 1966, certain employees of Vitson Mills, who were allegedly prevented from working due to the picketing, filed a civil suit for injunction in the Court of First Instance (CFI) presided by respondent Judge Walfrido delos Angeles. The complaint explicitly mentioned the strike declared on June 19, 1966. The CFI issued a restraining order on July 5, 1966, and later a writ of preliminary injunction on July 14, 1966, enjoining the union from obstructing access to the company.
The labor union moved to dismiss the civil case, arguing that the CFI had no jurisdiction because a labor dispute involving unfair labor practice charges was already pending before the CIR. Respondent Judge denied the motion to dismiss, seemingly persuaded by the plaintiffs’ framing of the suit as a protection of their individual private rights to access their workplace, distinct from the overarching labor dispute.

ISSUE

Whether or not the Court of First Instance had jurisdiction to issue injunctive relief in a suit filed by individual employees arising from a labor dispute where unfair labor practice charges were already pending before the Court of Industrial Relations.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. The legal logic is anchored on the principle of exclusive jurisdiction vested in the Court of Industrial Relations over labor disputes involving unfair labor practice charges, as provided under the Industrial Peace Act (Republic Act No. 875). The Court emphasized that the jurisdiction of the CIR cannot be evaded or emasculated by clever procedural stratagems, such as recasting a clearly labor-related controversy as a suit for the protection of private rights.
The fact that the civil suit was filed by individual employees and named the company as a defendant did not alter the fundamental nature of the case. The relief sought—to stop picketing that arose directly from the strike—was intrinsically connected to the pending labor dispute. The Supreme Court found that the respondent Judge’s assumption of jurisdiction ignored a long line of unequivocal precedents, starting with Reyes v. Tan, which consistently held that ordinary courts lack jurisdiction to enjoin picketing arising from a labor dispute when unfair labor practice charges are pending before the CIR. The attempt to separate the individual employees’ claims from the collective labor dispute was an artificial and unsustainable distinction. Consequently, the Supreme Court granted the writs of certiorari and prohibition, nullified the CFI’s orders, and directed the dismissal of the civil case.