G.R. No. L-30152. April 29, 1976.
Margarito Villacorta and Marine Stevedores Union, petitioners, vs. Hon. Reynaldo Honrado, Judge of the Court of First Instance of Surigao del Sur, and Southeast Stevedoring Company, Inc., respondents, Diatagon Arrastre Workers and Stevedores Union, intervenor-respondent.

FACTS

On January 7, 1969, petitioners filed an unfair labor practice charge with the Court of Industrial Relations (CIR) in Davao against respondent Southeast Stevedoring Co., Inc. The charge alleged that union members, upon discovery of their affiliation, were dismissed and denied wages and workmen’s compensation claims, creating a labor dispute that led to peaceful picketing at the company’s operations in Lianga, Surigao del Sur. This case was docketed as Charge No. 246 ULP-DB.
Six days later, on January 13, 1969, the respondent company filed a civil action for damages with a prayer for a preliminary injunction in the Court of First Instance (CFI) of Surigao del Sur. The complaint alleged that petitioners, through threats, intimidation, and the use of hired individuals, were unlawfully interfering with the company’s exclusive stevedoring contract with Lianga Bay Logging Co., Inc., aiming to force a cancellation of that contract and its award to them. The CFI, after hearings, issued a writ of preliminary injunction on January 23, 1969. Petitioners then filed the instant petition for certiorari and prohibition to restrain the CFI and nullify the injunction.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain the civil action for damages and injunction, or whether jurisdiction properly pertained to the Court of Industrial Relations due to the pendency of an unfair labor practice case arising from the same factual milieu.

RULING

The Supreme Court granted the petition, holding that the CFI acted without jurisdiction. The legal logic is anchored on the doctrine of exclusive jurisdiction. When the allegations in a civil case are intrinsically connected to or interwoven with an unfair labor practice dispute, jurisdiction is vested exclusively in the Court of Industrial Relations, to the exclusion of regular courts. This exclusivity applies regardless of which case was filed first.
Here, the factual circumstances underpinning both the CIR charge and the CFI complaint are inextricably linked. The CIR charge centers on alleged anti-union acts (dismissals, non-payment) leading to a labor dispute and picketing. The CFI complaint, while framed as a tortious interference with contract, essentially arises from the same core conflict: the union’s actions to gain stevedoring work, which the company characterizes as illegal coercion. The Supreme Court found that the acts complained of in the CFI—the threats, intimidation, and interference—were mere incidents of the broader labor dispute over employment terms and union recognition already pending before the CIR. Consequently, the CFI lost authority to proceed. The existence of the unfair labor practice charge divested the CFI of jurisdiction. The proper forum to resolve all intertwined issues, including the preliminary injunctive relief sought, was the CIR. The writ of preliminary injunction issued by the CFI was therefore nullified, and the CFI was directed to dismiss its civil case.