GR 28621; (February, 1971) (Digest)
G.R. No. L-28621 February 22, 1971
MAXIMO LEOQUINCO, ET AL., plaintiffs-appellants, vs. CANADA DRY BOTTLING COMPANY OF THE PHILIPPINES, INC., EMPLOYEES ASSOCIATION, ET AL., defendants-appellees.
FACTS
Plaintiffs-appellants, employees of Canada Dry Bottling Company, filed a complaint in the Court of First Instance of Rizal. They alleged that on August 23, 1967, and subsequent days, defendant individuals, who were officers and members of the defendant labor association, used force and intimidation to prevent them from reporting to work. This deprivation allegedly caused them to lose their wages. They claimed public officers could not provide adequate protection. They prayed for a writ of preliminary and permanent injunction to stop the obstruction and sought payment of lost wages and damages. The CFI initially granted a preliminary injunction.
The defendants-appellees moved for reconsideration, arguing the case arose from a labor dispute and was thus within the exclusive jurisdiction of the Court of Industrial Relations (CIR). They pointed to an existing unfair labor practice case (CIR Case No. 4824-ULP) filed against the company and some plaintiffs, who were managerial employees, and noted a strike began on August 23, 1967. They contended the acts complained of were part of the picketing during this strike.
ISSUE
Whether the Court of First Instance had jurisdiction over the complaint for injunction and damages filed by the employees, or if jurisdiction was vested in the Court of Industrial Relations because the case arose from a labor dispute.
RULING
The Supreme Court affirmed the dismissal of the case by the CFI for lack of jurisdiction, holding that the CIR had exclusive jurisdiction. The legal logic is anchored on the nature of the dispute and the applicable laws governing labor relations at the time. The complaint, while framed as one for damages and injunction due to alleged individual torts, was inextricably linked to a labor dispute. The Court found that the acts preventing the plaintiffs from working were committed in the course of a strike and picketing activity undertaken by the defendant union. The existence of a pending unfair labor practice case in the CIR involving the same company and some plaintiffs confirmed the industrial context.
Jurisdiction is determined by the allegations of the complaint and the nature of the relationship from which the controversy springs. Since the acts complained of were committed in furtherance of a strike arising from a labor dispute, the case fell under the exclusive jurisdiction of the CIR pursuant to Commonwealth Act No. 103 , as amended. The CIR was the specialized body equipped to appreciate the social and economic aspects of labor disputes and to grant appropriate relief, including incidental remedies like injunction in proper cases. The CFI correctly dismissed the case, as it could not interfere with matters within the CIR’s exclusive domain. The award of the injunction bond to the defendants was, however, eliminated as it was not justified by the mere dismissal on jurisdictional grounds.