GR 120465; (September, 1999) (Digest)
March 11, 2026AM RTJ 00 1564; (July, 2001) (Digest)
March 11, 2026G.R. No. L-12530; May 30, 1958
CONSOLIDATED LABOR ASSOCIATION OF THE PHILIPPINES, MANUEL E. SADDE, JUANITA SAN PEDRO, FELISA BUNA, GREGORIO GARCIA, ENCARNACION ARPILER, CRISTINA ARCEGA, BENITA CARPIO and ERLINDA SEGOVIA, petitioners, vs. THE HON. HERMOGENES CALUAG, LA CAMPANA FOOD PRODUCTS, INC., SY GO and RICARDO, JUANITA, MARIA, JOSE and PACITA, all surnamed TANTONGCO, doing business under the name and style of “La Campana Starch Packing,” respondents.
FACTS
Petitioner Consolidated Labor Association of the Philippines (the Association) is a registered labor organization whose members include employees of respondent employers (La Campana Food Products, Inc., et al.). Prior to July 3, 1957, the Association had instituted a certification election case (No. 17-MC) in the Court of Industrial Relations (CIR). On July 3, 1957, the employers dismissed several employees who were officers and active members of the Association. On July 5, 1957, the Association’s members made demands upon the employers, went on strike, and began picketing the factory. On July 9, 1957, the Association commenced a case (No. 1072-V) in the CIR against the employers, alleging unfair labor practices, violations of labor laws, and demanding reinstatement of dismissed employees, observance of the Eight-Hour Labor Law, payment of back overtime wages, and observance of the Minimum Wage Law. On July 10, 1957, at 3:46 p.m., a CIR acting prosecutor filed a formal complaint (case No. 1371 ULP) charging the employers with unfair labor practice, specifically for dismissing union officers and members and refusing to bargain, and prayed for cease and desist orders, reinstatement with back wages, and other relief.
Earlier on July 10, 1957, the employers instituted Civil Case No. Q-2482 in the Court of First Instance of Rizal (Quezon City Branch), presided by respondent Judge Hermogenes Caluag, against the petitioners. The complaint alleged that during the strike and picketing, petitioners committed unlawful acts including force, coercion, intimidation, and obstruction. It prayed for a writ of preliminary injunction and damages. That same afternoon, respondent Judge, after a hearing where only the plaintiffs and their counsel appeared (the defendants had not been served summons but their president, Manuel E. Sadde, appeared to ask for a postponement to notify counsel, which was denied), received the testimony of plaintiff Ricardo Tantongco and issued an order granting a writ of preliminary injunction restraining the defendants from the alleged unlawful acts.
Petitioners filed the present petition for certiorari and prohibition to restrain respondent Judge from hearing Civil Case No. Q-2482, to set aside the writ of preliminary injunction, and to enjoin further proceedings in that case.
ISSUE
Whether the Court of First Instance (respondent Judge) had jurisdiction to take cognizance of Civil Case No. Q-2482 and issue the writ of preliminary injunction, considering that unfair labor practice charges arising from the same labor dispute were already pending before the Court of Industrial Relations.
RULING
No. The Court of First Instance had no jurisdiction. The order issuing the writ of preliminary injunction is annulled and set aside, and the writ of preliminary injunction issued by the Supreme Court is made permanent.
The Supreme Court held that the allegations in the employers’ complaint before the Court of First Instance essentially involved or were intertwined with the unfair labor practice case pending before the CIR. The acts complained of (e.g., picketing, alleged intimidation) were incidents of the strike which was called due to the alleged unfair labor practices (the dismissals). Since the CIR had already acquired jurisdiction over the unfair labor practice case (No. 1371 ULP) filed by the CIR prosecutor, which included a prayer for reinstatement and other affirmative relief, the CIR had exclusive jurisdiction to issue any injunctive relief necessary, including restraining violent or coercive acts in connection with the dispute. The policy of the Industrial Peace Act (Republic Act No. 875) is to concentrate jurisdiction over labor disputes, including related incidents, in the CIR to prevent multiplicity of suits and conflicting rulings. The Court found that the CIR prosecutor’s filing of the complaint was not groundless, as indicated by the respondents’ subsequent agreement on August 15, 1957, to return all union members and not abet a company union. Therefore, the respondent Judge acted without jurisdiction in entertaining the case and issuing the injunction.

