G.R. No. L-21049 May 30, 1972
UNITED CENTRAL & CELLULOSE LABOR ASSOCIATION (PLUM), YBARRA TEVES, MOISES TAVITA and EPIFANIO EQUIO, petitioners, vs. HON. JUDGE MACARIO P. SANTOS of the CFI of Negros Oriental, ALLIED WORKERS’ ASSOCIATION BAIS CHAPTER, MARCIANO ABA, CENTRAL AZUCARERA DE BAIS, and COMPAÑIA CELLULOSA DE FILIPINAS, respondents.

FACTS

Petitioner United Central & Cellulose Labor Association (UCCLA) was the certified bargaining agent for workers of respondent companies. Collective bargaining agreements (CBAs) contained union shop clauses requiring employees who were members as of a certain date to maintain membership in UCCLA as a condition of employment. After the 1957 CBA expired on June 30, 1961, a strike ensued, leading to a return-to-work agreement and a new CBA effective July 1, 1961, with a similar union shop clause. On July 1, 1961, 168 workers, members of respondent Allied Workers’ Association (AWA), resigned from UCCLA and requested the companies to stop deducting union dues from their pay.
Subsequently, UCCLA demanded the dismissal of these workers under the union shop clause. The workers filed a declaratory relief action in the Court of First Instance (CFI) to enjoin their dismissal and the continued dues checkoff. Meanwhile, prior and subsequent unfair labor practice (ULP) cases involving the same parties and issues—including charges of company domination, illegal CBAs, and interference with union membership—were filed and pending with the Court of Industrial Relations (CIR).

ISSUE

Whether the CFI has jurisdiction over the declaratory relief action concerning the union shop clause and checkoff, or if jurisdiction lies exclusively with the CIR because the case involves a labor dispute with allegations of unfair labor practices.

RULING

The Supreme Court ruled that the CFI had no jurisdiction; exclusive jurisdiction belongs to the CIR. The legal logic is anchored on the nature of the controversy. The action, though framed as one for declaratory relief, fundamentally concerns the interpretation and enforcement of a union shop clause in a CBA and the concomitant checkoff of union dues. These matters are intrinsically linked to a labor dispute and allegations of unfair labor practices, such as interference with the right to self-organization and illegal dismissal threats under the guise of a union shop.
The Court emphasized that jurisdiction is determined by the allegations in the complaint and the relief sought. The workers’ claims directly challenge the validity and application of the CBA provision, questioning the legality of forced affiliation and dues deduction—issues that are at the heart of the pending ULP cases before the CIR. Under the Industrial Peace Act, the CIR has exclusive jurisdiction over cases involving unfair labor practices and disputes arising from the interpretation or implementation of CBAs. The checkoff issue, while potentially actionable separately under the Minimum Wage Law, is deemed an incident of the main union shop dispute. Therefore, to avoid multiplicity of suits and conflicting decisions, the entire controversy must be adjudicated by the industrial court. The CFI’s assumption of jurisdiction was a grave abuse of discretion. The writs of certiorari and prohibition were granted, and the preliminary injunction was made permanent.