G.R. No. L-33910 August 19, 1988
SILVA PIPE WORKERS UNION-NATU, petitioner, vs. FILIPINO PIPE & FOUNDRY CORPORATION and HON. PEDRO C. NAVARRO, respondents.

FACTS

Respondent Filipino Pipe & Foundry Corporation filed a complaint for damages with a prayer for a preliminary injunction before the Court of First Instance (CFI) of Rizal against petitioner Silva Pipe Workers Union-NATU. The company sought to enjoin the ongoing strike, have the picket lines lifted, declare the strike illegal, and claim damages, alleging the union was preventing ingress and egress and committing unlawful acts. The CFI issued an ex-parte temporary restraining order.
The union moved to dismiss the CFI case, arguing jurisdiction lay with the Court of Industrial Relations (CIR) as the dispute involved an unfair labor practice. The CFI denied the motion. Meanwhile, the company itself filed an unfair labor practice complaint against the union before the CIR. The CFI later declared the union in default for not filing an answer, prompting this petition for certiorari and prohibition to nullify the CFI proceedings.

ISSUE

Whether the Court of First Instance had jurisdiction over the complaint for damages and injunction arising from the strike, or if jurisdiction was exclusively vested in the Court of Industrial Relations.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. Jurisdiction was exclusively vested in the CIR because the company’s cause of action in the civil case arose from, and was interwoven with, an unfair labor practice dispute. The Court emphasized that the company’s own subsequent filing of an unfair labor practice complaint before the CIR unequivocally established the labor dispute nature of the case.
The legal logic is grounded on the exclusive jurisdiction provision of the Industrial Peace Act ( Republic Act No. 875 ). The Court rejected the company’s argument that the CFI could take cognizance because the suit aimed to prevent violent and unlawful acts. It held that even acts of violence, intimidation, or coercion alleged in a complaint are within the purview of the CIR’s exclusive jurisdiction when they are incidents of an underlying unfair labor practice case. Citing precedents, the Court explained that since strikes and picketing may be mere consequences of an unfair labor practice, any injunction related to that labor dispute must originate from the court (the CIR) with jurisdiction over the main case. Therefore, the CFI acted without jurisdiction. The Petition was granted, the CFI’s temporary restraining order and all proceedings were declared null and void, and the CFI was permanently enjoined from further action except to dismiss the case.