G.R. No. L-25003 October 23, 1981
LIWAYWAY PUBLICATIONS, INC., plaintiff-appellee, vs. PERMANENT CONCRETE WORKERS UNION, et al., defendants-appellants.

FACTS

Liwayway Publications, Inc., a second sublessee with a separate, fenced compound and entrance within the premises of Permanent Concrete Products, Inc., filed an action for injunction and damages in the Court of First Instance (CFI) of Manila. The complaint alleged that during a strike declared by the Permanent Concrete Workers Union against their employer, Permanent Concrete Products, Inc., the union members, without any legal justification, picketed and physically prevented Liwayway’s trucks and employees from entering its own separate compound to load newsprint from its bodega. This blockade caused Liwayway to incur additional expenses for renting a temporary bodega and transporting newsprint.
The defendant Union moved to dismiss the complaint, arguing that the CFI lacked jurisdiction. They contended the case arose from a labor dispute and fell under the exclusive jurisdiction of the Court of Industrial Relations (CIR). They also argued Liwayway was not the real party-in-interest, claiming the dispute was solely with their employer, Permanent Concrete Products, Inc., and that Liwayway’s remedy, if any, lay against its sublessor under the Civil Code.

ISSUE

Whether the Court of First Instance had jurisdiction to issue an injunction and award damages against the striking union for acts committed against a third-party entity with which it had no employer-employee relationship.

RULING

Yes, the CFI properly exercised jurisdiction. The Supreme Court affirmed the lower court’s decision. The legal logic rests on the absence of a labor dispute between the parties. For the CIR to have exclusive jurisdiction, the case must involve an employer-employee relationship or a labor dispute as defined by law. Here, Liwayway Publications and the defendant Union were complete strangers; there was no employer-employee relationship whatsoever. The union’s strike and primary dispute were with Permanent Concrete Products, Inc. Their act of blocking Liwayway’s access to its own, separate premises was an independent tort—a clear case of trespass (perturbacion de mero hecho) against a neutral third party. Such an action for damages and injunction due to tortious interference is within the regular courts’ jurisdiction.
The Court rejected the argument that Liwayway’s remedy was solely against its sublessor under Article 1654 of the Civil Code. That article pertains to a lessor’s warranty against legal trespass (perturbacion de derecho), where a third party claims a right. The union members claimed no right over Liwayway’s leasehold; their acts constituted a mere act of trespass. Under Article 1664 of the Civil Code, the lessee (Liwayway) has a direct action against the intruder (the Union). The CFI, therefore, correctly took cognizance of the case, issued the permanent injunction, and awarded actual damages, attorney’s fees, and costs to the appellee.