G.R. No. 148924, September 24, 2003
Toyota Motor Phils. Corporation Workers’ Association (TMPCWA), Petitioner, vs. Court of Appeals (Fourth Division) Justices Roberto Barrios, Ramon Mabutas and Edgardo Cruz, and Toyota Motor Phils. Corporation, Respondents.

FACTS

The Secretary of Labor ordered a certification election for Toyota’s rank-and-file employees. During the election, the union (TMPCWA) challenged the eligibility of 105 voters, claiming they were supervisory employees based on a prior Supreme Court ruling. These votes were segregated. The union garnered 503 “Yes” votes against 440 “No” votes. Excluding the 105 challenged votes, the union claimed a majority. Toyota insisted the challenged votes, from employees under a new “Three-Function Salary Structure,” were valid and should be opened, arguing the union lacked a majority if they were counted.
The Med-Arbiter ruled the challenged votes were from rank-and-file employees and ordered them opened. The union appealed to the Secretary of Labor, who assumed jurisdiction over the dispute and ordered the votes impounded pending resolution. Toyota then filed a petition for certiorari with the Court of Appeals (CA) against the Secretary’s order and also sought a writ of preliminary injunction to prevent the union from being certified as the bargaining agent.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in granting the writ of preliminary injunction.

RULING

Yes, the Court of Appeals gravely abused its discretion. A writ of preliminary injunction is an extraordinary remedy requiring a clear showing of an urgent necessity to prevent irreparable injury to the applicant before the main issue can be resolved. The Supreme Court found no such urgency existed. The core dispute—the eligibility of the 105 challenged votes—was already pending resolution before the Secretary of Labor, who had properly assumed jurisdiction. The union’s certification was held in abeyance pending this resolution, so no imminent, irreparable harm to Toyota was present.
Critically, during the CA hearings, the union’s counsel explicitly manifested under oath that the union would not strike over the representation issue and would await the Secretary’s final ruling. This solemn guarantee removed any perceived emergency or pressing necessity for injunctive relief. The CA’s grant of the injunction, despite this uncontroverted undertaking and the absence of any showing that the union would defy the Secretary’s authority, was a capricious and whimsical exercise of power. The injunction was therefore nullified.