G.R. No. L-7771-73, May 31, 1955
PHILIPPINE MOVIE PICTURES WORKERS’ ASSOCIATION, petitioner, vs. PREMIERE PRODUCTIONS, INC., respondent.

FACTS

The petitioner, Philippine Movie Pictures Workers’ Association (Association), is a labor organization whose members were employees of the respondent, Premiere Productions, Inc. (Company). On October 2, 1951, the Company filed a petition with the Court of Industrial Relations (CIR) to lay off about 44 personnel from three departments due to business losses. Presiding Judge Arsenio C. Roldan granted the petition after an ocular inspection and conference with the personnel. After shutting its studios, the Company sought CIR permission to lease its equipment and facilities to third parties (Eddie Infante, Braulio Calma, and others). The Association objected, arguing this would disturb the status quo in their pending dispute. The Company withdrew its petition, claiming leasing was a proprietary right needing no court permission. Subsequently, the Company leased equipment to Artemio Marquez, Efren Reyes, and Manuel Vistan for filming various movies. The Association filed three separate urgent petitions for contempt and injunction (Incidental Cases Nos. 98 V-8, 598 V-10, and 598 V-11), alleging the Company needed court authority for these leases. The cases were heard jointly. On October 7, 1952, after a stipulation of facts, both parties submitted the cases for decision but requested time for collective bargaining negotiations. During negotiations, the Association filed a supplemental petition to annul lease contracts and for contempt (April 18, 1953) and a motion for production of documents (June 14, 1953). Commissioner Martin Dolorico filed a report, which Judge Roldan adopted in his July 29, 1953 decision. Judge Roldan found the leases genuine and valid, reasoning that leasing idle equipment could help the Company rehabilitate and potentially re-employ laid-off personnel, who were promised reinstatement and backpay if the layoff was later deemed improper. He denied the three petitions for injunction and contempt, ordering the supplemental petition and motion to be heard separately. The Association moved for reconsideration. The CIR in banc, by resolution dated November 13, 1953 (penned by Judge Jose Bautista, concurred by Judges Castillo and Yanson), set aside Judge Roldan’s decision as premature, stating the trial court should have awaited further evidence on the supplemental petition. Judge Roldan dissented, concurred by Judge Juan E. Lanting. The Association filed petitions for certiorari to review both Judge Roldan’s decision and the CIR en banc resolution, seeking to declare the leases illegal and hold the Company in contempt.

ISSUE

Whether the petitions for certiorari are proper given that the CIR en banc resolution setting aside the trial judge’s decision left the cases without a final decision and is interlocutory in nature.

RULING

The Supreme Court denied the petitions for certiorari and remanded the cases to the CIR for further proceedings. The majority held that it was unnecessary to address the merits because the CIR en banc resolution setting aside Judge Roldan’s decision left the cases without a final decision to appeal from. The resolution was deemed a mere interlocutory order, not subject to appeal. No costs were awarded.
Concurring Opinion (Justice A. Reyes):
Justice Reyes concurred but emphasized that the remand should be for the specific purpose of having the CIR en banc render a decision without further evidence, as the Association had impliedly waived further presentation by seeking a decision from the Supreme Court based on existing evidence.