G.R. No. L-29385 March 15, 1971
FLORENTINO TAMAYO, ET AL., plaintiffs-appellees, vs. MANILA CORDAGE WORKERS UNION, ETC., and MANILA CORDAGE COMPANY, defendants, MANILA CORDAGE WORKERS UNION, ETC., defendant-appellant.

FACTS

Sixteen employees of Manila Cordage Company, all members of the Iglesia ni Cristo, joined the Manila Cordage Workers Union in December 1962 due to a union security clause in a newly executed Collective Bargaining Agreement (CBA). Their religious sect prohibits affiliation with any labor organization. Invoking Republic Act No. 3350 , which amended the Industrial Peace Act ( Republic Act No. 875 ) to exempt members of such sects from compulsory union membership agreements, they resigned from the Union on December 26, 1962. In June 1964, the Union demanded the Company terminate the employees for violating the CBA’s union shop clause. The Company notified the employees but did not effect dismissal. The employees filed a complaint in the Court of First Instance of Manila seeking to enjoin their dismissal, arguing their resignation was protected by law. The Company, in its answer, sought a declaration of the parties’ rights under the CBA in light of the amendatory law.

ISSUE

The primary issue is whether the Court of First Instance (regular court) had jurisdiction over the case, or if jurisdiction properly belonged to the Court of Industrial Relations as an unfair labor practice case.

RULING

The Supreme Court reversed the lower court’s judgment, holding it lacked jurisdiction. The legal logic is anchored on the exclusive jurisdiction of the Court of Industrial Relations (CIR) over unfair labor practice cases under the Industrial Peace Act. The Court, citing its recent ruling in Lakas Ng Manggagawang Makabayan vs. Abiera, established that a dispute concerning whether employees belonging to a religious sect can be dismissed for severing union membership despite a union security clause constitutes an unfair labor practice case. The amendatory Republic Act No. 3350 , which created the religious exemption, is an integral part of the statutory provisions defining unfair labor practices. Specifically, the Act makes it an unfair labor practice for a labor organization to cause an employer to discriminate against an employee where membership was terminated on grounds other than the usual union terms—a category that includes termination due to religious belief as protected by the amendment. The Industrial Peace Act explicitly vests the CIR with exclusive jurisdiction to prevent any unfair labor practice. Consequently, the employees’ suit to vindicate their statutory right under Republic Act No. 3350 , which directly relates to a union security clause and potential discriminatory dismissal, falls within the exclusive domain of the CIR. The regular court had no jurisdiction to adjudicate the matter. The Supreme Court raised this jurisdictional issue motu proprio as it goes to the very authority of the court to render judgment.