G.R. No. L-28389 and G.R. No. L-29079, March 15, 1971
TIONG SAN EMPLOYEES UNION and FEDERATION OF HOTELS, RESTAURANTS AND GENERAL WORKERS UNION OF THE PHILIPPINES, petitioners, vs. ANDRES LAO, SR., doing business under the name and style of TIONG SAN BAZAAR and the COURT OF INDUSTRIAL RELATIONS, respondents. / FEDERATION OF HOTELS, RESTAURANTS & GENERAL WORKERS OF THE PHILIPPINES, et al., petitioners, vs. THE HONORABLE MANUEL P. BARCELONA, PRESIDING JUDGE OF BRANCH VIII OF THE COURT OF FIRST INSTANCE OF MANILA and ANDRES LAO, Sr., respondents.

FACTS

The consolidated cases originated from a labor dispute at Tiong San Bazaar in Baguio City. On July 10, 1967, employees affiliated with the Tiong San Employees Union and its mother federation staged a strike. In response, owner Andres Lao, Sr. filed a petition for injunction with the Court of Industrial Relations (CIR) on July 18, 1967 (Case No. 219-Inj.), seeking to restrain picketing and alleged coercive acts. The CIR issued a preliminary injunction ex-parte on July 25, 1967. The unions moved to dismiss, arguing the CIR lacked jurisdiction as the petition did not allege unfair labor practice, making it a simple injunction case for regular courts.
Subsequently, on July 29, 1967, Lao filed charges of unfair labor practice (ULP) against the unions and individual members with the CIR (leading to Case No. 4765-ULP). The unions claimed this was an “afterthought” to confer jurisdiction after the jurisdictional challenge. Meanwhile, separate ULP cases were already pending against Lao filed by the unions (Cases Nos. 4736-ULP and 4803-ULP) concerning alleged dismissals of union members. Concurrently, Lao also filed a separate civil action for damages with the Court of First Instance (CFI) of Manila arising from the same strike.

ISSUE

The primary issues were: (1) whether the CIR had jurisdiction to issue the preliminary injunction in Case No. 219-Inj.; and (2) whether the CFI of Manila could properly take cognizance of the separate civil action for damages filed by Lao.

RULING

The Supreme Court affirmed the CIR’s jurisdiction and dismissed the petition against the CFI. On the first issue, the Court held that the CIR validly acquired jurisdiction to issue the injunction. Jurisdiction is determined by the allegations in the complaint. While Lao’s initial petition for injunction did not explicitly allege ULP, the subsequent filing of formal ULP charges on July 29, 1967, and the existence of previously filed ULP cases (Nos. 4736-ULP and 4803-ULP) between the same parties, integrated the injunction case into the broader labor dispute. Citing established doctrine, the Court ruled that once a ULP case is filed, the CIR acquires exclusive jurisdiction over all related matters, including claims for damages and injunctive relief arising from the same facts. Therefore, the CIR’s injunction order was proper.
On the second issue, the Court upheld the CFI’s jurisdiction over the separate civil action for damages. The Court clarified that while the CIR has exclusive jurisdiction over claims for damages arising from ULP, a claim for damages arising from “acts of violence, coercion, or intimidation” committed in the course of a strike can be pursued independently in regular courts. The nature of the action, not the parties’ relationship, determines jurisdiction. Since Lao’s CFI complaint