G.R. No. L-34761 January 17, 1974
CHAN BROS., INCORPORATED, plaintiff-appellee, vs. FEDERACION OBRERA DE LA INDUSTRIA TABAQUERA Y OTROS TRABAJADORES DE FILIPINAS (FOITAF) & FREE DEMOCRATIC LABOR UNION, LIWAYWAY GAUGAU, defendants-appellants.

FACTS

Chan Bros., Incorporated filed a complaint for injunction and damages in the Court of First Instance against the defendant labor unions, alleging illegal picketing on its premises. The plaintiff corporation admitted that the picket lines were directed against another entity, Liwayway Gaugau & Coffee Repacking, which shared the same premises, but denied any connection with that firm. The defendants moved to dismiss the case for lack of jurisdiction, asserting that a labor dispute existed and that unfair labor practice cases involving the same parties were already pending before the Court of Industrial Relations (CIR). They argued that the strike and picketing were outgrowths of these long-standing industrial disputes.
The lower court denied the motion to dismiss, proceeded to hear the case, and ultimately ruled in favor of Chan Bros. It enjoined the picketing and held the defendant unions liable for damages. The labor unions appealed directly to the Supreme Court, contending that the lower court acted without jurisdiction over the subject matter of the complaint.

ISSUE

Whether the Court of First Instance had jurisdiction over the complaint for injunction and damages arising from picketing that was interwoven with an unfair labor practice case pending before the Court of Industrial Relations.

RULING

The Supreme Court reversed the decision of the lower court, holding that it lacked jurisdiction. The legal logic is anchored on the exclusive jurisdiction of the Court of Industrial Relations (CIR) over cases involving unfair labor practices under Section 5(a) of Republic Act No. 875 (The Industrial Peace Act). The Court reiterated the settled doctrine that when the issues in a complaint for injunction are interwoven with or related to an unfair labor practice case already pending before the CIR, jurisdiction belongs exclusively to the industrial court. This rule applies even if the complaint alleges acts of violence, intimidation, or coercion.
In this case, the defendants correctly pointed out that unfair labor practice cases involving the same labor dispute were pending before the CIR prior to the filing of the civil complaint. The plaintiff’s own allegations showed the picketing was connected to a strike arising from the dispute with Liwayway Gaugau, an entity with which Chan Bros. shared premises. The Supreme Court cited controlling precedents, such as Philippine Association of Free Labor Unions vs. Quicho, which categorically states that a Court of First Instance cannot take cognizance of an injunction case where the issue is interwoven with a pending unfair labor practice case. Consequently, the lower court should have dismissed the complaint outright for lack of jurisdiction. The Supreme Court also noted the policy implications, emphasizing that allowing lower courts to assume jurisdiction and impose damages in such contexts could severely undermine the protective constitutional mandate for labor and the right to picket.