G.R. No. L-75736 September 29, 1988
ASSOCIATED LABOR UNIONS (ALU-TUCP), (For And In Behalf Of Its Direct Members, Namely, WARREN MAPUTI, RODRIGO CATIPAY, GILBERTO REDOBLADO ROBERTO RONOLO and 134 Others), petitioners, vs. HONORABLE ANTONIO V. BORROMEO AND BELYCA CORPORATION, Represented By BELLO M. CASANOVA, SR., President & General Manager, respondents.

FACTS

The petitioner union filed a notice of strike against Belyca Corporation, a livestock firm, on June 24, 1986, alleging unfair labor practices. It subsequently filed a formal complaint and went on strike on July 24, 1986. On the same day, the private respondent corporation filed a complaint for injunction with the Regional Trial Court, alleging that the striking workers were obstructing ingress to the farm premises, thereby preventing the feeding of approximately 7,500 hogs and 8,000 fowls and threatening the animals’ survival. The respondent judge immediately issued a temporary restraining order (TRO) commanding the strikers to allow access for feeding the animals.
The petitioner filed a motion for reconsideration and to dismiss the case for lack of jurisdiction, which the judge denied. Subsequently, the judge granted the corporation’s motion to extend the TRO for another twenty days, despite the petitioner’s opposition. The petitioner then elevated the case to the Supreme Court via a petition for certiorari and prohibition.

ISSUE

Whether the Regional Trial Court had jurisdiction to issue a temporary restraining order and entertain the injunction suit arising from a labor dispute involving a strike.

RULING

The Supreme Court granted the petition, declaring the assailed orders null and void. The legal logic is firmly rooted in the doctrine of primary jurisdiction. The Court held that courts of law have no jurisdiction to act on labor cases or incidents arising therefrom. Under Article 217 of the Labor Code, as amended, Labor Arbiters possess original and exclusive jurisdiction over cases involving unfair labor practices, terms and conditions of employment, money claims of workers, and cases arising from any violation of the Code, including questions involving the legality of strikes and lockouts. The injunction suit filed by the corporation was intrinsically interwoven with the labor dispute concerning the strike’s legality and alleged unfair labor practices, matters exclusively cognizable by the labor tribunal.
The Court further ruled that the respondent judge committed grave abuse of discretion. First, by extending the TRO beyond the statutory twenty-day limit prescribed by Batas Pambansa Blg. 224, which mandates that a TRO automatically expires by force of law after twenty days if no preliminary injunction is issued. Second, by allowing the TRO to be used as an instrument to counter the strike’s impact based on the employer’s concern for property (the animals), which would effectively frustrate the very right to strike. The power to determine which strikes may be enjoined is vested by law in the Secretary of Labor, not the regular courts. The Court concluded that the judge allowed himself to be used as an instrument to undermine the strike, and reprimanded the corporation’s counsel for manipulating court processes.