G.R. No. L-18371. April 23, 1963.
FIL-HISPANO LABOR UNION, PHILIPPINE TRANSPORT AND GENERAL WORKERS ORGANIZATION, PABLO ZACARIAS, DOMINGO MARTIN and ROBERTO S. OCA, petitioners, vs. THE HON. JUDGE AGUSTIN P. MONTESA, FIL-HISPANO CERAMICS, INC., FIL-HISPANO LABOR UNION (PAFLU), NICASIO CABUANG, ROBERTO SIOSON, RICARDO GAMBOA, BENJAMIN BAUTISTA, D.B. TUAZON and FELIMON MENDOZA, respondents.

FACTS

The Fil-Hispano Labor Union, composed of employees of Fil-Hispano Ceramics, Inc., was originally affiliated with the Philippine Association of Free Labor Unions (PAFLU). Following an election of new union officers, the union passed a resolution disaffiliating from PAFLU and affiliating with the Philippine Transport and General Workers Organization (PTGWO). PAFLU responded by suspending the elected officers and placing the union under a trusteeship committee. The company subsequently entered into a collective bargaining agreement with this PAFLU trusteeship committee and refused to remit check-off union dues to the petitioners’ union.
On April 22, 1961, the petitioners’ union and PTGWO filed an unfair labor practice charge against the company with the Court of Industrial Relations (CIR), alleging refusal to bargain and to turn over union dues. Simultaneously, the union declared a strike. Two days later, on April 24, the company and the PAFLU-affiliated union filed a complaint in the Court of First Instance (CFI) of Bulacan against the petitioners, seeking an injunction to restrain them from allegedly molesting or interfering with company employees. Respondent Judge Agustin P. Montesa issued the requested ex-parte writ of preliminary injunction on the same day.

ISSUE

Whether the Court of First Instance of Bulacan had jurisdiction to issue the ex-parte writ of preliminary injunction in a case involving a labor dispute where an unfair labor practice charge was already pending before the Court of Industrial Relations.

RULING

The Supreme Court granted the petition, annulled the writ issued by the CFI, and made permanent the preliminary injunction it had earlier issued against the respondent Judge. The Court ruled that the CFI acted without jurisdiction. The core legal logic is grounded on the doctrine of primary jurisdiction. At the time the CFI complaint was filed, a charge for unfair labor practice was already pending before the CIR. The acts complained of in the CFI—alleged molestation and interference with employees during a strike—were intimately related to and arose from the same labor dispute that formed the subject of the unfair labor practice charge. Consequently, jurisdiction over the entire controversy, including any injunctive relief related to the strike activities, vested exclusively in the CIR to the exclusion of the regular courts.
Even assuming, arguendo, that the CFI had concurrent jurisdiction, the issuance of the injunction was still fatally defective for non-compliance with the mandatory conditions under Section 9(d) of Republic Act No. 875 (The Industrial Peace Act). This law strictly governs the issuance of injunctions in labor disputes. It requires a hearing, the reception of testimonial evidence, and express findings by the court on specific statutory prerequisites, such as the threat of unlawful acts, substantial and irreparable injury to property, and the lack of an adequate remedy at law. The respondent Judge issued the writ ex-parte without any such hearing or findings, thereby acting in excess of jurisdiction. The Supreme Court emphasized that the procedural safeguards of RA 875 are indispensable and cannot be bypassed.