G.R. No. L-24224 July 30, 1965
MALAYANG MANGGAGAWA SA ESSO (PFPW) and PHILIPPINE FEDERATION OF PETROLEUM WORKERS, petitioners, vs. ESSO STANDARD EASTERN, INC., and HON. CARMELINO G. ALVENDIA, Judge of the Court of First Instance of Manila, respondents.

FACTS

The respondent, ESSO, is a foreign corporation engaged in marketing petroleum products in the Philippines. It had a collective bargaining agreement with the Citizens Labor Union (CLU), effective until July 8, 1966. Another labor organization, the Malayang Manggagawa sa Esso (MME), filed a petition for certification election with the Court of Industrial Relations (CIR) on January 7, 1965, claiming to represent a majority of ESSO’s employees at its Pandacan terminal. Hearings on this petition were ongoing when, on February 19, 1965, MME declared a strike at the terminal. On February 22, ESSO filed a petition for injunction in the Court of First Instance of Manila against MME and its affiliate, the Philippine Federation of Petroleum Workers (PFPW). The CFI, presided by Judge Carmelino G. Alvendia, issued an ex parte preliminary injunction on the same day, ordering the respondents to refrain from continuing the strike, picketing, and other concerted activities as long as the certification election case was pending. MME then filed this original action for certiorari with the Supreme Court to have the injunctive order set aside.

ISSUE

Whether the Court of First Instance of Manila had jurisdiction to issue the preliminary injunction against the strike and picketing, or whether such jurisdiction belonged exclusively to the Court of Industrial Relations.

RULING

The Supreme Court granted the writ of certiorari and set aside the CFI’s order. The Court held that the CFI acted without jurisdiction. The controversy between the two rival unions, CLU and MME, over which should be the exclusive bargaining agent constituted a labor dispute as defined by the Industrial Peace Act ( Republic Act No. 875 ). ESSO became virtually a party to this dispute when it intervened in the certification election case before the CIR by moving to dismiss MME’s petition. The strike declared by MME was an incident interwoven with this pending certification case. Furthermore, ESSO’s allegation in its petition that MME struck to compel it to discriminate against CLU was an allegation of an unfair labor practice, which also falls under the exclusive jurisdiction of the CIR. Therefore, the authority to issue an injunction in connection with the strike pertained exclusively to the CIR. The CFI’s ex parte injunction, issued under the Rules of Court instead of the strict procedural requirements of the Industrial Peace Act, and which enjoined the protected rights to strike and picket in their entirety, was issued without jurisdiction. The Supreme Court made its own preliminary injunction permanent.