GR L 13965; (May, 1960) (Digest)
G.R. No. L-13965; May 23, 1960
CONSTANTINO LEDUNA, ET AL., petitioners, vs. HONORABLE EDUARDO D. ENRIQUEZ, Judge of Court of First Instance of Negros Occidental and SAN CARLOS MILLING COMPANY, LTD., respondents.
FACTS
Respondent San Carlos Milling Company, Ltd. (the company) filed an ejectment suit (Civil Case No. 4449) in the Court of First Instance of Negros Occidental against petitioners (the employees) to recover possession of company houses. The company alleged the employees had voluntarily ceased working and thus forfeited their employment status and attendant housing privileges. The employees, in their answer, contended their work stoppage was due to their participation in an unfair labor practice strike declared by their union against the company on April 12, 1956, and that they remained employees. They noted the related unfair labor practice case (CIR Case No. 3-ULP-Iloilo) was pending before the Court of Industrial Relations (CIR). The parties stipulated that the employees were provided free housing, had ceased work since the strike date, and the labor dispute was pending in the CIR. At a subsequent hearing where the employees and their counsel failed to appear, respondent Judge rendered a decision in favor of the company. The court later granted the company’s motion for immediate execution. The employees filed a motion for new trial, citing their counsel’s excusable negligence (a mailed motion for postponement arrived late) and arguing the decision was contrary to law and unsupported by evidence. They also later informed the court that on April 30, 1958, the CIR had rendered a decision finding the company guilty of unfair labor practice and ordering the immediate reinstatement of the employees with back wages. The lower court denied the motion for new trial and a subsequent motion for reconsideration. A writ of execution was issued, leading the sheriff to proceed with the ejectment. The employees then filed this petition for certiorari with a prayer for a mandatory preliminary injunction.
ISSUE
Whether the Court of First Instance (respondent Judge) acted without or in excess of jurisdiction or with grave abuse of discretion in proceeding with and deciding the ejectment case and in ordering the execution of its decision, despite the pendency and subsequent favorable resolution of the related unfair labor practice case before the Court of Industrial Relations which involved the core issue of the employees’ status.
RULING
Yes. The Supreme Court granted the petition. The Court held that the main issue in the ejectment case—whether the employees had lost their status as such—was intrinsically linked to and dependent upon the outcome of the unfair labor practice case pending before the CIR, which has exclusive jurisdiction over such matters. The respondent Judge should have suspended the ejectment proceedings pending the final resolution of the CIR case. This was especially imperative after the CIR rendered its decision finding the company guilty of unfair labor practice and ordering the reinstatement of the employees. The Court noted that under Section 6 of Republic Act No. 875 (the Industrial Peace Act), an appeal from a CIR reinstatement order does not stay its execution. Therefore, the CIR’s reinstatement order was prima facie proof of the employees’ continued status and should have prevailed. The respondent Judge’s failure to grant a new trial and reconsideration in light of the CIR decision constituted a grave abuse of discretion. The Supreme Court set aside the decision and orders of the respondent Judge in the ejectment case.
