G.R. No. L-29785. January 28, 1971.
MANILA STEVEDORING AND GENERAL WORKERS UNION (PTGWO), petitioner, vs. HON. GREGORIO T. LANTIN, Judge of the Court of First Instance of Manila; BENITO G. NAVARRO; NATIONAL WORKERS AND STEVEDORING UNION; PHILIPPINE STEAM NAVIGATION COMPANY, and EMILIANO ROMEO, respondents.

FACTS

Respondents Benito Navarro and the National Workers and Stevedoring Union filed a civil suit for breach of contract and damages in the Court of First Instance (CFI) of Manila against the Philippine Steam Navigation Company, Emiliano Romeo, and petitioner Manila Stevedoring and General Workers Union. The complaint alleged that Navarro had a valid stevedoring contract with the Company, which was disrupted when the Manila Union, representing Romeo’s workers, staged a strike. The Company subsequently entered into a return-to-work agreement with the Manila Union, which Navarro claimed effectively prevented him and his union from performing their contractual stevedoring work, causing them financial damage. They sought damages, annulment of the return-to-work agreement, restoration to work, and an injunction.
The petitioner Manila Union moved to dismiss the CFI case on jurisdictional grounds, asserting that the dispute involved a labor matter over which the Court of Industrial Relations (CIR) had exclusive jurisdiction. The Manila Union had previously filed an unfair labor practice charge against the Company with the CIR, alleging refusal to bargain. The respondent CFI judge denied the motion to dismiss, prompting the Manila Union to file this petition for certiorari.

ISSUE

Whether the Court of First Instance has jurisdiction over the civil case for breach of contract and damages filed by Navarro and the National Union, or whether jurisdiction lies exclusively with the Court of Industrial Relations because the case involves a labor dispute.

RULING

The Supreme Court denied the petition, upholding the CFI’s jurisdiction. The legal logic is that jurisdiction is determined by the allegations in the complaint. Navarro’s complaint essentially avers a violation of a commercial stevedoring contract and the tortious interference by the Manila Union through acts of violence and intimidation, causing pecuniary loss. These are ordinary civil claims for breach of contract and damages. The mere allegation by the Manila Union that the case involves a labor dispute or that an employer-employee relationship exists—which is central to CIR jurisdiction—is insufficient to divest the CFI of jurisdiction. The complainant’s theory of the case controls for jurisdictional purposes. The Court noted that the CIR case filed by the Manila Union did not implead Navarro or his union, so any CIR decision would not bind them. While this may lead to the undesirable possibility of two courts (CFI and CIR) potentially ruling on the related issue of employer-employee relationship, this is an unavoidable consequence of the parties’ conflicting claims. The CFI may later dismiss the case if evidence presented during trial substantiates that an employer-employee relationship and an unfair labor practice are at the core of the dispute, but such a determination cannot be made merely on the pleadings. The preliminary injunction was dissolved.