G.R. No. L-10333; July 25, 1957
ASSOCIATED WATCHMEN AND SECURITY UNION (PTWO), CATALINO P. ROSALES and ROBERTO OCA, petitioners, vs. UNITED STATES LINES, AMERICAN PRESIDENT LINES, MACONDRAY & CO., ET AL., respondents.

FACTS

The respondents, who are shipping agents in the Philippines for various vessels, filed a complaint in the Court of First Instance of Manila. They alleged that the petitioner labor union commenced picketing their vessels at the Manila South Harbor on February 18, 1956, to coerce them into a collective bargaining agreement regarding watchmen. The respondents claimed they were not the employers of the watchmen, as they had individually contracted with several watchmen agencies as independent contractors to perform the guarding work, and they had no authority to hire or dismiss the watchmen. Upon filing a bond, the trial court issued a writ of preliminary injunction restraining the petitioners from picketing and interfering with the respondents’ business. The petitioners challenged this writ via certiorari, contending that their dispute with the respondents constituted a “labor dispute” under Section 9 of Republic Act No. 875 (the Magna Charta of Labor), and thus the injunction was issued without the required statutory procedures.

ISSUE

Whether the trial court acted without or in excess of jurisdiction and with grave abuse of discretion in issuing the writ of preliminary injunction without first determining if a “labor dispute” existed under Republic Act No. 875 .

RULING

Yes. The Supreme Court set aside the trial court’s order. The Court found that a “labor dispute” existed within the meaning of Section 2(j) of Republic Act No. 875 , which defines it as including any controversy concerning terms or conditions of employment, “regardless of whether the disputants stand in the proximate relation of employer and employee.” The fact that the watchmen’s services were contracted and paid for through agencies, but were ultimately availed of and paid by the steamship agencies, meant they worked for the respondents. The allegation in the complaint that no employer-employee relationship existed was a conclusion of law that could not negate the existence of a labor dispute. Consequently, the trial court was required to follow the specific procedures under Section 9 of Republic Act No. 875 before issuing an injunction. By issuing the injunction without such a hearing and determination, the court exceeded its jurisdiction. Furthermore, even assuming doubt on the issue, it was an abuse of discretion to issue the injunction without a prior hearing to receive evidence on whether a labor dispute existed, as this determination dictates the applicable legal procedure. The writ of preliminary injunction was declared null, and the preliminary injunction issued by the Supreme Court in favor of the petitioners was made permanent.