G.R. No. L-27585 May 29, 1970
PROGRESSIVE LABOR ASSOCIATION (PLA) assisted by its Mother Federation PHILIPPINE ASSOCIATION OF FREE LABOR UNION (PAFLU), plaintiffs-appellants, vs. ATLAS CONSOLIDATED MINING AND DEVELOPMENT CORPORATION, ASSOCIATED LABOR UNION (ALU) DEMOCRITO T. MENDOZA, CECILIO T. SENO, ALEXANDER P. NILLAS, MANUEL ENRIQUEZ, ALBERTO TROCIO, ILUMINADO G. TANTOY, DEPARTMENT OF LABOR RELATIONS, defendants-appellees.

FACTS

The Progressive Labor Association (PLA), claiming to be the duly certified exclusive bargaining representative of the employees of Atlas Consolidated Mining and Development Corporation, filed a complaint in the Court of First Instance of Rizal. PLA alleged that after its duly elected officers assumed office and presented demands to the company, a strike was called on July 11, 1966. During the strike, defendants Alexander P. Nillas, Manuel Enriquez, Alberto Trocio, and Iluminado G. Tantoy, allegedly conspiring with Democrito T. Mendoza and Cecilio T. Seno of the Associated Labor Union (ALU), declared themselves to be the officers of PLA. Mendoza and Seno, misrepresenting themselves as authorized representatives of PLA, entered into a Return-to-Work Agreement with Atlas on August 27, 1966, which was attested to by the Department of Labor and Bureau of Labor Relations. The complaint alleged that the duly elected officers of PLA had not abandoned their posts, that the defendants were usurpers, and that Atlas’s act of entering into the agreement was a violation of law and the existing Collective Bargaining Agreement, causing demoralization among union members and encroaching on their rights to self-organization and concerted activity. PLA prayed for the annulment of the Return-to-Work Agreement, a declaration that the defendants’ acts were illegal, and an award of damages. The defendants moved to dismiss the case on the ground that the subject matter fell within the jurisdiction of the Court of Industrial Relations (CIR). The lower court granted the motion to dismiss, prompting PLA’s appeal.

ISSUE

Whether the Court of First Instance had jurisdiction over the case, or whether jurisdiction properly belonged to the Court of Industrial Relations.

RULING

The Supreme Court affirmed the order of dismissal, ruling that jurisdiction properly lay with the Court of Industrial Relations. The Court held that the determination of court jurisdiction over the subject matter is based on the allegations of the complaint. A reading of the complaint showed that the acts complained of involved the unauthorized assumption of union officer positions and the unauthorized representation of the union in a labor agreement with the employer. The case would require a determination of which set of officers had the authority to represent the employees—a matter of internal union procedure cognizable by the CIR—and an assessment of the company’s good or bad faith in entering the agreement. The complaint’s allegations, particularly that the company’s act violated law and the collective bargaining agreement and encroached on the members’ rights to self-organization and concerted activity, clearly raised issues of unfair labor practice. Since the cause of action arose from or was intertwined with alleged unfair labor practices, jurisdiction was vested in the CIR. The Court noted that PLA had even filed a separate unfair labor practice case in the CIR involving the same acts. The appellants’ argument that their demand for damages could not be entertained by the CIR was unavailing, as the right to damages would depend on evidence presented in the unfair labor practice case, and to hold otherwise would sanction split jurisdiction, which is prejudicial to the orderly administration of justice.