G.R. No. 12820 , December 20, 1957
SMB BOX FACTORY WORKER’S UNION (PAFLU), petitioner, vs. HON. JUDGE GUSTAVO VICTORIANO, of the Court of First Instance of Rizal, and GONZALO SANCHEZ, respondents.

FACTS

On August 2, 1957, respondent Gonzalo Sanchez filed an action (Civil Case No. 4655) in the Court of First Instance of Rizal against the members of the petitioner union. Sanchez, who claimed to be an independent contractor for the San Miguel Brewery Box Factory, sought to enjoin the union members from committing acts of violence and intimidation during picketing and to recover damages. He alleged that after a strike settlement on July 2, 1957, the union members struck again on August 8, 1957, resuming picketing with violent acts that prevented non-striking workers from working. The union moved to dismiss the complaint, arguing lack of jurisdiction. They contended that an unfair labor practice case was already pending before the Court of Industrial Relations (CIR) involving the same box factory and the same labor dispute, wherein the issue of whether Sanchez was an independent contractor or an agent of San Miguel Brewery, Inc. was raised. The CFI judge, without receiving testimonial evidence, granted a preliminary injunction against the union. The union then filed this certiorari petition to enjoin the enforcement of that injunction, claiming the CFI had no jurisdiction as the matter involved an unfair labor practice under the exclusive jurisdiction of the CIR.

ISSUE

Whether the Court of First Instance of Rizal had jurisdiction to take cognizance of Civil Case No. 4655 (the action for injunction and damages filed by Gonzalo Sanchez) and issue a preliminary injunction therein, considering a related unfair labor practice case was pending before the Court of Industrial Relations.

RULING

No. The Supreme Court granted the petition, set aside the writ of preliminary injunction issued by the CFI, and made permanent its own preliminary injunction. The Court held that the CFI had no jurisdiction over the case. The subject matter of Sanchez’s action was interwoven with the issue in the pending unfair labor practice case before the CIR, which involved the same labor dispute and the same parties regarding the relationship between Sanchez and the corporation. Following the precedent in National Garments and Textiles Worker’s Union-Paflu vs. Hon. Hermogenes Caluag, et al., the Court ruled that even if the complaint alleged acts of violence, the case fell under the exclusive jurisdiction of the CIR because the main issue was intertwined with an unfair labor practice case. Furthermore, even assuming arguendo that the CFI had jurisdiction, the preliminary injunction was void because it was issued without following the specific procedure mandated by Section 9(d) of Republic Act No. 875 (the Magna Carta of Labor) for labor disputes. The CFI erroneously followed Rule 60, Section 6 of the Rules of Court and granted the injunction without the requisite hearing and findings required under the labor law.