G.R. No. L-11722; November 28, 1959
PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), DOMINGO S. BAUTISTA, ET AL., plaintiffs-appellants, vs. ROY PADILLA, ALICIO LUISON and ANGEL R. PAEZ, defendants-appellees.

FACTS

The plaintiffs, PAFLU and some employees who are members of the National Miners and Allied Workers Union (NAMAWU), filed a complaint in the Court of First Instance of Camarines Norte against the officers of NAMAWU (Roy Padilla, Alicio Luison, and Angel R. Paez). The action was designated as “accounting and recovery of money with preliminary injunction.” The complaint alleged that the defendant officers failed to submit proper monthly financial reports, submitted an incomplete statement of income and expenses unsupported by vouchers, incurred a deficiency, allotted exorbitant salaries to themselves without proper approval, affiliated NAMAWU with another federation (PTUC) without first disaffiliating from PAFLU, and refused to surrender their positions after suspension. The plaintiffs sought an accounting, annulment of unauthorized acts, declaration of nullity of the disqualification and new affiliation, ouster of the defendants, and injunctive relief. The defendants moved to dismiss the complaint, primarily on the ground that the court lacked jurisdiction over the subject matter. The lower court, after the parties confined their arguments to the jurisdictional issue, granted the motion to dismiss without prejudice to filing in the proper court. The plaintiffs appealed directly to the Supreme Court.

ISSUE

Whether the Court of First Instance had jurisdiction over the subject matter of the action, which involved allegations of anomalies, irregularities, and violations committed by union officers against their union’s constitution and by-laws.

RULING

The Supreme Court affirmed the order of dismissal, holding that the Court of First Instance correctly dismissed the complaint for lack of jurisdiction. The Court ruled that the anomalies and irregularities alleged in the complaint constituted violations of internal labor organization procedures as expressly outlined in Section 17 of Republic Act No. 875 (the Industrial Peace Act). These included the rights of members to detailed financial reports, the proper collection and disbursement of funds, and the procedures for officer compensation. Since Section 2 of the same Act defines “Court” as the Court of Industrial Relations for purposes of the Act, jurisdiction over actions involving violations of these internal procedures is vested exclusively in the Court of Industrial Relations, not the regular courts. Therefore, the lower court’s dismissal was proper.