GR 87700; (June, 1990) (Digest)
G.R. No. 87700, June 13, 1990
SAN MIGUEL CORPORATION EMPLOYEES UNION-PTGWO, ET AL., petitioners, vs. HON. JESUS G. BERSAMIRA, IN HIS CAPACITY AS PRESIDING JUDGE OF BRANCH 166, RTC, PASIG, and SAN MIGUEL CORPORATION, respondents.
FACTS
Petitioner Union, the certified bargaining agent for San Miguel Corporation’s (SMC) monthly paid rank-and-file employees, demanded that SMC regularize workers from Lipercon and D’Rite, independent service contractors. The Union alleged these workers, performing tasks necessary to SMC’s business for extended periods, were engaged in a “labor-only” contracting scheme. After SMC did not comply, the Union filed notices of strike for unfair labor practice and CBA violations, leading to conciliation at the National Conciliation and Mediation Board (NCMB) and subsequent picketing by the contractual workers.
SMC filed a Complaint for Injunction and Damages with the Regional Trial Court (RTC) to enjoin the Union from representing the contractual workers, calling a strike vote, inducing pickets, and other related acts. The RTC, finding the complaint sufficient, issued a Writ of Preliminary Injunction. The Union filed this certiorari and prohibition action, asserting the RTC lacked jurisdiction as the case involved a labor dispute.
ISSUE
Whether the Regional Trial Court had jurisdiction to issue the Writ of Preliminary Injunction, or whether jurisdiction properly belonged to labor tribunals.
RULING
The Supreme Court ruled that the RTC acted without jurisdiction. The core of SMC’s complaint was inextricably linked to a labor dispute. The Union’s demand for regularization and the ensuing strike notices centered on the classification and rights of workers, constituting an unfair labor practice case and issues involving terms and conditions of employment. Under Article 217 of the Labor Code, as it stood prior to its 1989 amendment, labor arbiters possessed original and exclusive jurisdiction over such cases, including unfair labor practices and questions involving the legality of strikes.
The Court rejected SMC’s argument that its action was a simple claim for damages under the Civil Code. The alleged damages were interwoven with the underlying labor dispute; to allow the civil action to proceed would create an impermissible “split jurisdiction.” While recognizing SMC’s management prerogative to contract out work, the Court emphasized the constitutional rights of workers to self-organization and collective bargaining. The proper venue for resolving the intertwined issues of contracting legitimacy, regularization, and associated damages was the labor relations system. The challenged orders were set aside, and the RTC was enjoined from further action except to dismiss the case.