G.R. No. L-17692; July 20, 1961
KAISAHAN NG MGA MANGGAGAWA SA LA CAMPANA (KKM), petitioner, vs. HON. HERMOGENES CALUAG, ETC., ET AL., respondents.

FACTS

The Court of Industrial Relations (CIR) issued a final order in 1957 in a labor case, directing the reinstatement of workers and payment of back wages. After the order became executory, the petitioner union secured a writ of execution from the CIR. The respondents, Ricardo Tantongco and La Campana Food Products, Inc., failed to comply, leading to contempt proceedings. The respondents previously filed a petition for certiorari and prohibition with the Supreme Court (G.R. No. L-13119) to restrain the contempt charge, but it was denied in 1959.
Subsequently, the CIR issued another writ of execution in 1960. To prevent its enforcement, the respondents instituted an action for prohibition with a petition for preliminary injunction in the Court of First Instance (CFI) of Quezon City, presided by Judge Hermogenes Caluag (Civil Case No. Q-5047). The petitioner union moved to dismiss the CFI case for lack of jurisdiction over the subject matter, arguing that the CIR’s orders and writs were within its exclusive domain. Despite this motion, the respondent judge directed the filing of an answer, compelling the petitioner to seek relief from the Supreme Court via certiorari and prohibition.

ISSUE

Whether the Court of First Instance of Quezon City has jurisdiction to entertain an action for prohibition aimed at nullifying a writ of execution issued by the Court of Industrial Relations and restraining its enforcement.

RULING

The Supreme Court ruled that the respondent CFI had no jurisdiction over the subject matter. The legal logic is anchored on the principle of judicial hierarchy and the co-equal rank of courts. The Court of Industrial Relations is a court of record, statutorily conferred with jurisdiction over labor disputes, and is equal in rank to a Court of First Instance. A fundamental rule of procedure is that a court cannot issue writs of injunction or prohibition against another court of coordinate or equal rank. Such prerogative writs are supervisory in nature and may only be issued by a superior court to a tribunal, officer, or person exercising judicial, quasi-judicial, or ministerial functions lower in rank.
Therefore, the CFI, being of equal standing with the CIR, lacked the authority to nullify the CIR’s writ of execution or to restrain its enforcement through an injunction. The proper remedy for the respondents, if they believed the CIR acted without jurisdiction or with grave abuse of discretion, was to elevate the matter directly to the Supreme Court via the appropriate extraordinary writ. The Supreme Court granted the petition, making the writ of certiorari and prohibition permanent, and set aside the CFI’s proceedings. It clarified that this decision was without prejudice to the respondents filing a separate ordinary action for the recovery of any alleged damages.