G.R. No. L-31390 April 15, 1988
FREE TELEPHONE WORKERS UNION, petitioner, vs. PHILIPPINE LONG DISTANCE TELEPHONE COMPANY and the HONORABLE COURT OF APPEALS, respondents.

FACTS

The Philippine Long Distance Telephone Company (PLDT) filed a complaint for damages against the Free Telephone Workers Union (FTWU) in the Manila Court of First Instance (CFI). PLDT alleged that the union staged a strike in violation of a “no-strike clause” in their collective bargaining agreement, causing actual damages. The Court of Industrial Relations (CIR) had previously assumed jurisdiction over the same strike, which the union claimed was a protest against unfair labor practices, and had issued a return-to-work order.
The CFI rendered judgment ordering the union to pay damages. The Court of Appeals affirmed this decision, rejecting the union’s arguments that the CFI lacked jurisdiction, that the case became moot when the strikers were accepted back to work, and that liability was improperly assessed. The union elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the Court of First Instance had jurisdiction over PLDT’s complaint for damages arising from a strike which was the subject of a labor dispute under the jurisdiction of the Court of Industrial Relations.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. The legal logic is anchored on the doctrine against splitting jurisdiction to ensure the orderly administration of justice. The Court, reiterating established precedent from Holganza v. Apostol and PLDT Co. v. Free Telephone Workers Union, held that complaints for damages arising from or intertwined with labor disputes, such as an illegal strike, fall within the exclusive jurisdiction of the Court of Industrial Relations (the specialized labor court at the time).
Since the CIR had already assumed jurisdiction over the strike—the very act alleged to constitute the breach of contract—the claim for damages resulting from that same strike was intrinsically connected to the labor dispute. Allowing the regular courts to adjudicate the damages claim would sanction split jurisdiction, where two different courts would rule on different aspects of the same controversy. This is prejudicial to judicial order and consistency. Consequently, the CFI’s judgment, having been rendered without jurisdiction, was a nullity. The Supreme Court reversed and set aside the decisions of the Court of Appeals and the CFI, and dismissed the civil case. The other arguments raised by the union were deemed unnecessary to resolve.