G.R. No. L-17838 August 3, 1966
NASIPIT LABOR UNION (MFL), petitioner, vs. COURT OF INDUSTRIAL RELATIONS, NASIPIT STEVEDORING CO., INC., and OLIVIO G. RUIZ, respondents.

FACTS

On March 22, 1960, the Nasipit Labor Union (NLU) filed a complaint for unfair labor practice with the Court of Industrial Relations (CIR) against Nasipit Stevedoring Co., Inc. and its president, Olivio G. Ruiz. The complaint alleged that on October 2, 1958, the parties entered into a collective bargaining agreement wherein the company would only employ union members for stevedoring work. It further alleged that in November 1958, the company convinced union officers to disaffiliate from the Mindanao Federation of Labor (MFL), and that in March 1959, union members were deprived of work for refusing to desist from membership. The union claimed the company acted in bad faith by entering into a new collective bargaining agreement with another union, the Young Men Labor Union Stevedores (YMLUS). The union prayed for a declaration of unfair labor practice, payment of back wages, and an order for the company to bargain in good faith.
Prior to this CIR case, the NLU had filed two cases in the Court of First Instance (CFI) of Agusan. On March 5, 1959, NLU and Cipriano Malonzo filed a complaint (Civil Case No. 699) for reformation of the collective bargaining agreement to exclude MFL, which was dismissed on March 25, 1959. On September 7, 1959, NLU and MFL filed another complaint (Civil Case No. 748) against the company and YMLUS for enforcement of the collective bargaining contract, with damages and injunction. This case was still pending when the CIR complaint was filed.
The respondents filed a motion to dismiss the CIR case on the grounds of another action pending in the CFI and lack of jurisdiction of the CIR. The CIR granted the motion to dismiss on September 8, 1960, citing the Supreme Court ruling in Philippine Sugar Institute vs. Court of Industrial Relations that the CIR lacks jurisdiction over suits to enforce collective bargaining agreements. The CIR denied the motion for reconsideration on October 27, 1960.

ISSUE

Whether the Court of Industrial Relations has jurisdiction over the complaint filed by the Nasipit Labor Union, which essentially seeks the enforcement of a collective bargaining agreement.

RULING

No. The Supreme Court affirmed the orders of the Court of Industrial Relations dismissing the case for lack of jurisdiction. The Court held that the CIR’s jurisdiction, as narrowed by Republic Act 875, is confined to specific cases: (1) labor disputes in industries indispensable to the national interest certified by the President; (2) controversies regarding the minimum wage under Republic Act 602; (3) issues involving hours of employment under Commonwealth Act 444; and (4) cases involving unfair labor practice under Section 5(a) of Republic Act 875. An action to enforce or for violation of a collective bargaining agreement is not among these enumerated instances. The Court found that the allegations of unfair labor practice were not bona fide but a maneuver to divest the CFI of jurisdiction over the pending enforcement case (Civil Case No. 748), noting the identity of parties and the relief prayed for in both the CIR and CFI cases. The Court reiterated its doctrine that the CIR is without jurisdiction over suits to enforce collective bargaining agreements, unless the action is interwoven with legitimate charges of unfair labor practice or involves minimum wage or hours of employment issues, which was not the case here.