G.R. No. L-17281; March 30, 1963
VICTORIAS MILLING COMPANY, INC., petitioner, vs. COURT OF INDUSTRIAL RELATIONS and FREE VISAYAN WORKERS (NEGROS BRANCH), respondents.

FACTS

Petitioner Victorias Milling Company, Inc., a corporation operating a sugar central and owning several sugar cane haciendas, refused to bargain collectively with respondent Free Visayan Workers Union. The Union had submitted proposals for a collective bargaining contract on behalf of laborers working in the company’s sugar cane plantations. The company’s refusal was based on its contention that the Industrial Peace Act ( Republic Act No. 875 ) is not applicable to agricultural workers. Consequently, the Union filed an unfair labor practice charge with the Court of Industrial Relations (CIR).
The CIR prosecutor filed a corresponding complaint. The milling company moved to dismiss the case, reiterating the inapplicability of the Industrial Peace Act to its agricultural workers. The CIR denied the motion to dismiss and ordered the company to answer. After the denial of its motion for reconsideration, Victorias Milling Company instituted the present action for prohibition.

ISSUE

The sole issue is whether the Industrial Peace Act ( Republic Act No. 875 ) applies to agricultural workers, thereby granting the CIR jurisdiction over the unfair labor practice case.

RULING

The Supreme Court ruled that the Industrial Peace Act does not apply to agricultural workers, and thus the CIR has no jurisdiction over the case. The legal logic is anchored on statutory interpretation and established jurisprudence. The Court first examined the definition of “employee” under Section 2(d) of Republic Act No. 875 , which explicitly excludes agricultural laborers. This exclusion is not merely obiter dictum but a clear legislative intent.
The Court further clarified that the nature of the work determines the classification. The members of the respondent Union were engaged in purely agricultural work—planting and harvesting sugar cane and performing incidental farming chores in the haciendas. They were not involved in the subsequent industrial milling process. Consequently, they are unequivocally agricultural laborers. The governing law for their relationship with the landholder is the Agricultural Tenancy Act ( Republic Act No. 1199 , as amended), and any disputes, including alleged unfair labor practices, fall under the exclusive jurisdiction of the Court of Agrarian Relations, as created by Republic Act No. 1267 .
This conclusion is reinforced by prior decisions, such as Santos v. CIR and Hacienda Esperanza v. CIR, which consistently held that unfair labor practice cases involving agricultural workers are within the exclusive domain of the agrarian court. The subsequent enactment of Republic Act No. 2263 , which granted agricultural workers the right to organize, merely confirmed this jurisdiction. Therefore, the CIR improperly assumed jurisdiction. The writ of prohibition was granted, the challenged order was set aside, and the CIR was ordered to desist from further proceedings in the case.