G.R. No. L-24388 July 29, 1968
REGAL MANUFACTURING EMPLOYEES ASSOCIATION and CELESTINO BAYLON, petitioners, vs. HON. ANDRES REYES, and PHILIPPINE METAL FOUNDRIES INC., (Formerly Regal Manufacturing Co., Inc.), respondents.

FACTS

The Philippine Metal Foundries, Inc. (the Company) and the Regal Manufacturing Employees Association (the Union) had a collective bargaining agreement containing “no strike” and “no lockout” provisions. On October 3, 1963, the Company dismissed Celestino Baylon, the Union president. The Union declared a strike and picketed the Company on October 5, 1963. On October 7, 1963, the Company filed a petition for injunction with the Court of First Instance (CFI) of Rizal, alleging the strike violated the agreement and involved blocking, threats, and violence. The CFI issued a restraining order on October 8. On the same date, the Union filed an unfair labor practice (ULP) case (3932-ULP) with the Court of Industrial Relations (CIR) against the Company for Baylon’s dismissal. On October 14, the Company filed a ULP case (3941-ULP) with the CIR against the Union, alleging violation of the agreement and an illegal strike. The Company later amended its CFI petition to include a claim for damages (actual, special, exemplary, and attorney’s fees) and a declaration that the strike was illegal with loss of employee status for participants. The petitioners filed an answer in the CFI case, asserting lack of jurisdiction due to the pending CIR cases. After petitioners and their counsel failed to appear at pre-trial, the CFI proceeded and rendered judgment on September 28, 1964, awarding damages to the Company and declaring the strike illegal with loss of employee status for participants. Petitioners’ subsequent petition for relief and motion for reconsideration were denied by the CFI in orders dated January 12 and February 18, 1965.

ISSUE

Whether the Court of First Instance had jurisdiction over the Company’s action for injunction and damages, considering the existence of pending unfair labor practice cases between the same parties before the Court of Industrial Relations.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. The action filed by the Company in the CFI was essentially a labor dispute involving an unfair labor practice, over which the CIR has exclusive jurisdiction under Republic Act No. 875 . The fact that the Company sought damages for alleged violations of the collective bargaining agreement arising from the strike did not divest the CIR of its jurisdiction. The claim for damages was inextricably linked to the unfair labor practice case pending before the CIR, and to allow the CFI to proceed would sanction split jurisdiction. The CFI should have dismissed the petition outright or, at the very least, suspended action on the question of damages until the CIR decided the ULP cases. Accordingly, the CFI decision of September 28, 1964, and its orders of January 12 and February 18, 1965, were annulled and set aside. The CFI was ordered to refrain from proceeding with the case on the question of damages until final judgment in the CIR ULP cases.