G.R. No. L-23745. January 22, 1975.
LITTON MILLS WORKERS UNION-NATU, petitioner, vs. THE HONORABLE SAMUEL F. REYES and LITTON MILLS, INC., respondents.

FACTS

Petitioner Litton Mills Workers Union-NATU declared a strike on November 2, 1964, against private respondent Litton Mills, Inc., alleging unfair labor practices consisting of discrimination and dismissal of union officers and members. The following day, November 3, 1964, respondent Judge Samuel F. Reyes of the Court of First Instance of Rizal, acting on a complaint for damages filed by the corporation, issued an ex parte writ of preliminary injunction. This writ broadly prohibited the striking employees from various acts related to their picketing, all without prior notice or hearing.
The union filed this certiorari and prohibition proceeding, asserting that respondent Judge acted without jurisdiction. It contended that since the dispute involved an alleged unfair labor practice, exclusive jurisdiction, including the power to issue injunctions, resided in the Court of Industrial Relations (CIR) under the Industrial Peace Act (Republic Act No. 875). The corporation, in its answer, denied the existence of a labor dispute or an employer-employee relationship pertinent to the injunction, characterizing the complaint as a simple action for damages arising from alleged violent and coercive acts during picketing, thus falling within the ordinary courts’ jurisdiction.

ISSUE

Whether or not the Court of First Instance had jurisdiction to entertain the complaint for damages and issue the preliminary injunction, or if exclusive jurisdiction belonged to the Court of Industrial Relations.

RULING

The Supreme Court ruled that the Court of First Instance had no jurisdiction; exclusive jurisdiction was vested in the Court of Industrial Relations. The legal logic is anchored on the interpretation of Section 5(a) of the Industrial Peace Act (RA 875), which granted the CIR exclusive jurisdiction over the prevention of unfair labor practices. The Court found that a labor dispute existed, and the union’s strike was explicitly grounded on allegations of unfair labor practices by the employer. While the corporation’s complaint framed the issue as one of damages from illegal picketing, the underlying context was inextricably linked to the labor dispute. Following settled doctrine, notably Reyes v. Tan and S.M.B. Box Factory Workers Union v. Judge Victoriano, once an element of an unfair labor practice is present, any related application for injunction becomes the exclusive domain of the CIR. Ordinary courts are thereby divested of jurisdiction. The respondent Judge’s assumption of jurisdiction and issuance of the ex parte injunction, without complying with the specific procedural requirements for labor injunctions under Section 9 of RA 875, constituted an act in excess of jurisdiction and with grave abuse of discretion. Consequently, the Supreme Court granted the petition and ordered the dismissal of the complaint in the Court of First Instance.