G.R. No. L-28978 September 22, 1971
ASSOCIATED LABOR UNION and AMORITO V. CAÑETE, petitioners, vs. JUDGE FERNANDO A. CRUZ, GOODYEAR TEXTILE MFG. Co., and NG TAY, respondents.

FACTS

Respondent Goodyear Textile Manufacturing Company filed a complaint for damages with a prayer for a preliminary injunction in the Court of First Instance of Rizal against petitioner Associated Labor Union. The company alleged that on October 25, 1967, Union members and non-employees conducted patrols around its premises, committing acts of intimidation, threats, coercion, and violence against executives and workers, thereby preventing free ingress and egress to the factory and causing daily financial losses. The lower court issued a restraining order enjoining the Union from maintaining these patrols.
The Union moved to dismiss the complaint, asserting that a labor dispute existed. It cited that a Notice of Strike had been filed and an actual strike commenced on October 25, 1967, with related picket lines. Furthermore, an unfair labor practice case (Case No. 4924-ULP) had subsequently been instituted by court prosecutors in the Court of Industrial Relations (CIR) against the Union, charging it with staging an illegal strike and committing coercive acts during picketing. The lower court initially dismissed the civil case but later reinstated the restraining order, prompting this certiorari petition.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain the complaint for damages and issue a restraining order against the Union’s picketing activities, given the existence of a labor dispute and a pending unfair labor practice case in the CIR.

RULING

The Supreme Court ruled that the Court of First Instance had no jurisdiction. The legal logic is anchored on the doctrine of primary jurisdiction of the Court of Industrial Relations over matters arising from or intertwined with labor disputes. The company’s claim for damages was fundamentally based on acts allegedly committed by the Union during the strike—specifically, the patrolling and picketing activities. The determination of the Union’s liability for these acts hinges on the legality or illegality of the strike and the conduct of the picket, which are questions directly connected to the unfair labor practice case pending before the CIR.
The Court emphasized that jurisdiction is conferred by law and is determined by the allegations in the complaint and the nature of the relief sought. Although the company’s civil complaint carefully avoided explicit mention of a labor dispute, the Union’s responsive pleadings and the subsequent filing of the unfair labor practice case in the CIR clearly revealed the underlying industrial controversy. Since the issue of damages was inextricably linked to the labor dispute, exclusive jurisdiction resided with the CIR. The lower court, upon being apprised of the labor dispute, should have dismissed the case or suspended proceedings pending the CIR’s final resolution. The order reinstating the injunction was therefore issued without jurisdiction and was reversed. The civil case was ordered dismissed without prejudice to the company’s right to seek appropriate relief after the termination of the CIR case.