G.R. No. L-15287 September 30, 1963
VIVENCIO JORNALES, ET AL., plaintiffs-appellants, vs. CENTRAL AZUCARERA DE BAIS and COMPAÑIA CELULOSA DE FILIPINAS, defendants-appellees.

FACTS

The plaintiffs-appellants, permanent employees of the defendants-appellees, filed a complaint in the Court of First Instance for illegal dismissal, specific performance of their employment contracts, reinstatement via mandatory injunction, and damages. They alleged their dismissal violated their employment agreements. The defendants justified the dismissals by invoking a collective bargaining agreement containing a closed-shop clause, which required employees to join the exclusive bargaining union, the United Central and Cellulose Labor Association (UCCLA). The defendants asserted that upon the plaintiffs’ failure to join the union within the stipulated period, and upon the union’s demand, they were constrained to terminate the plaintiffs’ employment.
The lower court, upon reviewing the complaint and its annexed documents—specifically the letters notifying the plaintiffs of the requirement to join the union and their subsequent dismissal for non-compliance—dismissed the case for lack of jurisdiction. It ruled that the claim for reinstatement was inextricably linked to a question of unfair labor practice, which falls under the exclusive jurisdiction of the Court of Industrial Relations (CIR). The plaintiffs appealed, arguing the court erred in considering the answer to determine jurisdiction and in dismissing the case sua sponte.

ISSUE

Whether the Court of First Instance had jurisdiction over the complaint for illegal dismissal and reinstatement, or whether the case involved an unfair labor practice falling within the exclusive jurisdiction of the Court of Industrial Relations.

RULING

The Supreme Court affirmed the dismissal, holding the lower court correctly declared it lacked jurisdiction. The legal logic turns on the nature of the act constituting the dismissal as pleaded by the plaintiffs themselves. While the appellants framed their action as one for specific performance of a private contract, the annexes to their complaint, which are deemed integral parts thereof, revealed the factual basis for dismissal: the employer’s enforcement of a closed-shop provision in a collective bargaining agreement at the union’s instance, resulting in termination for non-membership.
This factual allegation constitutes a clear statement of an unfair labor practice under Section 4(a)(4) of the Industrial Peace Act ( Republic Act No. 875 ), which prohibits an employer from discriminating in regard to tenure of employment to encourage or discourage union membership. When a dismissal is alleged to be discriminatory and linked to union activity or membership—even if it also breaches a private employment contract—it ceases to be a simple contractual violation. It implicates a public right or policy specially protected by labor law. The law provides a specific remedial procedure and vests exclusive original jurisdiction over the prevention of unfair labor practices, including claims for reinstatement arising therefrom, in the Court of Industrial Relations. Consequently, the Court of First Instance had no authority to adjudicate the claim. A court may dismiss a case ex mero motu once it determines it lacks jurisdiction over the subject matter, as jurisdiction is conferred by law and cannot be waived by the parties.