G.R. No. L-12000; August 30, 1958
Benguet Consolidated Mining Company, plaintiff-appellant, vs. Coto Labor Union, et al., defendants-appellees.

FACTS

On May 7, 1956, the Coto Labor Union, composed of employees of Benguet Consolidated Mining Company, declared a strike and set up pickets along the company’s private road and railroad tracks connecting its mining camp in Coto, Zambales, to its wharf. The company filed an action for injunction in the Court of First Instance of Manila, alleging that the strikers barricaded the road and tracks, used coercion, threats, and violence to obstruct ore trains and vehicles carrying necessities, and that a company foreman was stabbed to death. It further alleged that Constabulary soldiers could not provide adequate protection due to legal prohibitions on police interference in picketing. The lower court, without taking testimony under oath as required by Section 9(d) of Republic Act No. 875 , granted a preliminary injunction ex parte to restrain the obstruction. The defendants moved to lift the order, arguing it was issued without jurisdiction and without complying with the Act’s requisites. The court allowed the order to stand but qualified that it “must not be interpreted to prohibit peaceful picketing.” After issues were joined and contempt proceedings were initiated against defendants for alleged violations of the injunction, the Supreme Court issued decisions holding that the Court of Industrial Relations (CIR) had exclusive jurisdiction over cases involving unfair labor practice. Invoking these rulings, the defendants filed a motion to dismiss the complaint and the contempt proceedings, alleging the subject matter fell within the exclusive jurisdiction of the CIR because it was connected to unfair labor practice cases already pending there, and that the alleged contemptuous acts occurred beyond the injunction’s validity period. The lower court granted the motion to dismiss, prompting the company’s appeal.

ISSUE

Whether the Court of First Instance of Manila had jurisdiction to entertain the complaint for injunction and issue the preliminary injunction, considering the existence of pending unfair labor practice cases between the same parties before the Court of Industrial Relations.

RULING

No. The order of dismissal is affirmed. The Supreme Court held that the lower court acted without jurisdiction. It was admitted that when the strike was declared and the injunction suit was filed, there were already pending cases for unfair labor practice between the same parties before the CIR, and the strike was motivated by the acts complained of in those pending cases. Following established jurisprudence, particularly Lakas Ng Pagkakaisa Sa Peter Paul et al. vs. Judge Victoriano et al., the Court ruled that when a labor dispute is already involved in cases previously submitted to the CIR, a Court of First Instance has no jurisdiction to try a separate case for injunctive relief arising from the same dispute, to avoid multiplicity of actions. Any injunctive relief against acts of violence could be obtained from the CIR, which is vested with ample power under the law. Furthermore, the writ of preliminary injunction issued by the lower court was declared illegal for having been issued in disregard of the procedure prescribed in Section 9(d) of Republic Act No. 875 , which requires a hearing with presentation of testimonial evidence and an opportunity for cross-examination. The appellant’s contention that the acts sought to be enjoined had no relation to the strike was found to be without merit, as the complaint itself made it obvious that the obstructive acts were in furtherance of the strike. Costs were imposed against the appellant.