GR 33520; (May, 1977) (Digest)
G.R. No. L-33520 May 26, 1977
CYPHIL EMPLOYEES ASSOCIATION-NATU, petitioner, vs. PHARMACEUTICAL INDUSTRIES INC., and HON. ALBERTO J. FRANCISCO, Judge, Court of First Instance, Manila, respondents.
FACTS
The petitioner union filed a notice of strike against Cyanamid Philippines, Inc. due to alleged unfair labor practices, including interference with self-organization and refusal to bargain collectively. After conciliation failed, the union declared a strike on March 25, 1971, and established peaceful picket lines at the premises of Cyanamid and its sister firm, respondent Pharmaceutical Industries, Inc. On March 31, 1971, the respondent company filed a complaint for injunction with damages in the Court of First Instance of Manila. Respondent Judge Alberto J. Francisco issued an ex-parte restraining order, and later a writ of preliminary injunction, prohibiting the picketing.
The petitioner union moved to dismiss the complaint, asserting that the Court of First Instance lacked jurisdiction. The union argued that the case involved a labor dispute stemming from unfair labor practices, which was within the exclusive jurisdiction of the Court of Industrial Relations. Respondent Judge denied the motion to dismiss and upheld the injunction. The union then filed this certiorari proceeding before the Supreme Court.
ISSUE
Whether the Court of First Instance had jurisdiction over the complaint for injunction and damages arising from a strike allegedly caused by unfair labor practices.
RULING
The Supreme Court granted the petition for certiorari, ruling that the respondent Judge acted without jurisdiction. The legal logic is anchored on the doctrine of exclusive jurisdiction over labor disputes involving unfair labor practices. At the time, such disputes were exclusively cognizable by the Court of Industrial Relations, not regular courts.
The Court, citing Holganza v. Apostol and a line of precedents including Associated Labor Union v. Gomez and Progressive Labor Association v. Atlas Consolidated Mining, emphasized that to allow a regular court to adjudicate a claim for damages intertwined with an unfair labor practice dispute would sanction an impermissible “split jurisdiction.” This is prejudicial to the orderly administration of justice, as it would force the bifurcation of a single controversy between two different tribunals. The complaint, though artfully framed as one for injunction with damages, was intrinsically linked to the labor dispute. Therefore, the Court of First Instance should have dismissed the case for lack of jurisdiction.
Consequently, the Supreme Court made permanent its preliminary injunction, ordered the dismissal of Civil Case No. 82752, and held that the respondent Judge’s orders were void. The Court also noted, obiter, that the injunction against peaceful picketing was infirm, as peaceful picketing is a constitutionally protected freedom of speech, but this point required no extensive discussion given the dispositive jurisdictional ruling.