G.R. No. L-16884; January 31, 1963
NATIONAL MINES AND ALLIED WORKERS’ UNION, petitioner, vs. HON. MELQUIADES G. ILAO, Judge of the Court of First Instance of Camarines Norte, PARACALE-GUMAUS CONSOLIDATED MINING COMPANY, INC., and G. M. BUDISELIC, respondents.

FACTS

The Paracale-Gumaus Consolidated Mining Company had a valid closed-shop agreement with the Camarines Norte Confederation of Miners and Labor Association, its certified bargaining agent. In February 1960, the petitioner, National Mines and Allied Workers’ Union, filed a petition for certification election with the Court of Industrial Relations (CIR), alleging it now represented the majority of the company’s employees. Subsequently, in April 1960, the petitioner union also filed an unfair labor practice complaint with the CIR against the company, citing the dismissal of an employee under the closed-shop agreement as a discriminatory act.
While these two cases were pending before the CIR, the company filed a separate action for injunction with the Court of First Instance (CFI) of Camarines Norte to restrain the petitioner union from picketing and interfering with its labor relations under the existing closed-shop contract. The CFI judge, respondent Melquiades G. Ilao, issued an ex-parte writ of preliminary injunction against the union. The petitioner union then filed this certiorari proceeding to annul the injunction and challenge the CFI’s jurisdiction.

ISSUE

Whether the Court of First Instance had jurisdiction to issue a preliminary injunction in a labor dispute while certification election and unfair labor practice cases involving the same parties and subject matter were 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 doctrine of exclusive jurisdiction. When the petitioner union filed the certification election and unfair labor practice cases with the CIR, that court acquired exclusive jurisdiction over the labor dispute, including all incidents arising from it, such as related picketing activities. The CFI was thereby divested of any authority to interfere through an injunctive remedy. The issuance of the injunction by the CFI constituted an encroachment on the CIR’s specialized domain.
Furthermore, even assuming arguendo that the CFI had jurisdiction, the procedure followed in granting the injunction was legally defective. The judge issued the writ ex-parte. Under Section 9(d) of Republic Act No. 875 (The Industrial Peace Act), no preliminary injunction in a labor case can be issued without a hearing where testimony is received. The CFI’s reliance on the general provisions of the Rules of Court was erroneous, as the specific mandatory requirements of the labor law prevail. Consequently, the Supreme Court declared the writ of preliminary injunction void and prohibited the respondent judge from further taking cognizance of the civil case for injunction.