G.R. No. L-22180 October 23, 1974
PRUDENCIO JALANDONI, JOSE LIANSING, ANTONIO ADVINCULA and NUMERIANO OROCEO, petitioners, vs. THE HONORABLE DEMETRIO G. VINSON, Judge of the Court of First Instance, 12th Judicial district and ELIZALDE and COMPANY, INCORPORATED, respondents.

FACTS

Petitioners are officers of the National Sugar Workers Union (PAFLU), representing farm workers in three haciendas owned by respondent Elizalde & Company. A labor dispute arose, leading to a strike and picketing by the farm laborers on October 29, 1963. A complaint concerning this agrarian dispute was already filed with the Court of Agrarian Relations (CAR) in Bacolod City. The following day, October 30, 1963, Elizalde & Company filed a separate complaint for damages with the Court of First Instance (CFI) presided by respondent Judge Vinson, praying for a writ of preliminary injunction to restrain the picketing and demonstrations. Without a hearing, respondent Judge issued the injunction on October 31, 1963. Petitioners moved to dissolve the writ, arguing the CFI lacked jurisdiction as the dispute fell under the exclusive jurisdiction of the CAR. This motion, and a subsequent reiteration in their answer, were denied by respondent Judge.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain a complaint for damages and issue a preliminary injunction arising from a labor dispute involving farm workers and hacienda management.

RULING

The Supreme Court granted the petition for certiorari, ruling that the CFI acted without jurisdiction. The legal logic is anchored on the well-settled doctrine that disputes between farm laborers and agricultural management are exclusively cognizable by the Court of Agrarian Relations. This allocation of jurisdiction is rooted in the state’s police power to regulate agrarian relations and is in line with constitutional mandates for social justice and protection to labor. The Court cited a line of precedents, including Ferrer v. Villamor and Ojo v. Jamito, which firmly established that ordinary courts are devoid of authority over such agricultural labor disputes. The fact that the complaint was styled as one for damages did not divest the CAR of its exclusive jurisdiction, as the cause of action emanated directly from the strike and picketing activities integral to the agrarian dispute. Respondent Judge, upon the petitioners’ challenge to his jurisdiction, was obligated to conduct a preliminary hearing to determine the factual question of whether an agrarian tenancy or labor relation existed. His failure to do so and his insistence on exercising authority constituted a grave abuse of discretion. Consequently, the issued writ of preliminary injunction and the underlying orders were nullified, and the CFI was ordered to dismiss the complaint for lack of jurisdiction.