G.R. No. L-17196 December 28, 1961
TEODORICO B. SANTOS, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents.

FACTS

Adriano Calisin and other agricultural laborers filed a complaint for unfair labor practice against their employer, Teodorico B. Santos, with the Court of Industrial Relations (CIR). They alleged that they were dismissed from Santos’s 500-hectare hacienda because they affiliated with the Casaca Peasant Union. Santos moved to dismiss the complaint for lack of jurisdiction, arguing that as agricultural laborers, the complainants were not covered by Republic Act No. 875 , the Industrial Peace Act. The CIR deferred action on the motion and proceeded to trial.
After hearing, the CIR rendered a decision asserting jurisdiction over the case. It found Santos guilty of unfair labor practice and ordered the reinstatement of the complainants with back wages. Santos elevated the case to the Supreme Court via a petition for review, contesting the CIR’s jurisdiction.

ISSUE

The principal issue is whether the Court of Industrial Relations has jurisdiction over an unfair labor practice case involving agricultural laborers.

RULING

The Supreme Court ruled that the CIR has no jurisdiction. The legal logic is anchored on two key points. First, the term “employee” as defined in Section 2(d) of Republic Act No. 875 (the Industrial Peace Act) does not include agricultural laborers. The Court, citing its precedent in Boy Scouts of the Philippines v. Araos, clarified that such exemptions, while not explicitly stated in the Philippine law, are logically implied, mirroring exclusions found in analogous statutes like the U.S. Wagner Act. Therefore, agricultural laborers are not within the ambit of the Industrial Peace Act.
Second, matters pertaining to the relationship between landlord and tenant or agricultural worker fall under the exclusive jurisdiction of the Court of Agrarian Relations, as created by Republic Act No. 1267 . This court was vested with broad authority to settle all questions involving relationships established by law concerning the cultivation and use of agricultural land. The subsequent enactment of Republic Act No. 2263 , which granted agricultural workers the right to file such actions, merely confirmed this jurisdiction. Since the complainants were undisputedly agricultural laborers working on Santos’s hacienda, their grievance, even if couched as an unfair labor practice, was an incident of an agrarian relationship. Consequently, the proper forum was the agrarian court, not the industrial court. The Supreme Court set aside the CIR’s order for having been rendered without jurisdiction.