G.R. No. L-12587; November 27, 1959
BALAQUEZON TRANSPORTATION LABOR UNION, CHARTER VII-B, ET AL., petitioners, vs. HON. CECILIA MUÑOZ-PALMA, ETC., ET AL., respondents.

FACTS

In January 1957, the Balaquezon Transportation Labor Union (petitioner) filed several unfair labor practice complaints against the Laguna Tayabas Bus Company (respondent Company) in the Court of Industrial Relations (CIR), alleging interference with union activities and sponsorship of a company union (the Laguna Tayabas Bus Company Employee’s Association). On June 25, 1957, the petitioner union declared a strike. To resolve the paralyzing strike, the parties entered into a temporary agreement on July 6, 1957, supplemented by another on July 9, 1957, agreeing to hold a supervised election to determine which union would be the collective bargaining representative. The election was held on July 16-18, 1957, but the counting of ballots was stalled because the petitioner union’s president refused to surrender the keys to the ballot boxes, alleging interference by the Company. On July 22, 1957, the respondent Employee’s Association filed a case in the Court of First Instance (CFI) of Laguna seeking injunctive relief to, among other things, compel the surrender of the keys and the counting of ballots, and to prohibit the petitioner union from staging a strike. The CFI issued an ex parte preliminary writ of prohibitory injunction on the same day. The petitioner union then filed a petition for a certification election in the CIR on July 24, 1957, which remained pending. The petitioner union subsequently filed the present petition for certiorari and prohibition before the Supreme Court, challenging the CFI’s injunction.

ISSUE

Whether the Court of First Instance of Laguna had jurisdiction to issue the ex parte preliminary writ of prohibitory injunction in a case involving a labor dispute, without complying with the mandatory hearing requirements under Section 9(d) of Republic Act No. 875 (the Industrial Peace Act).

RULING

The Supreme Court ruled in favor of the petitioner union. The writs of certiorari and prohibition were granted, and the preliminary injunction issued by the Supreme Court was made final. The ex parte writ issued by the CFI was annulled and set aside.
The Court held that the case before the CFI undeniably involved a labor dispute. The controversy originated from unfair labor practice charges and a strike. The subsequent agreements to hold an election were temporary measures to resolve the strike but did not terminate the underlying labor dispute, as evidenced by the petitioner’s subsequent filing of another unfair labor practice charge and a petition for a certification election questioning the election results. The dispute over which union should represent the employees and administer the collective bargaining agreement falls within the statutory definition of a “labor dispute” under Section 2(j) of Republic Act No. 875 , which includes controversies concerning the representation of persons in negotiating terms of employment, regardless of whether the disputants stand in the proximate relation of employer and employee.
Since a labor dispute was involved, the CFI was bound by the procedural requirements of Section 9(d) of Republic Act No. 875 , which explicitly prohibits courts from issuing injunctions in such cases except after a hearing with testimony and cross-examination. The CFI’s issuance of the injunction ex parte, without such a hearing, was therefore irregular, illegal, and void for lack of jurisdiction.