G.R. No. L-24827. April 27, 1982.
FREE TELEPHONE WORKERS UNION, petitioner, vs. PHILIPPINE LONG DISTANCE TELEPHONE COMPANY and COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

The President certified a labor dispute between the Free Telephone Workers Union and the Philippine Long Distance Telephone Company to the Court of Industrial Relations (CIR) under CIR Case No. 51-IPA. On November 9, 1964, the CIR issued a partial decision granting a wage increase and, pursuant to Section 19 of Commonwealth Act No. 103 , ordered the union members to return to work immediately. The order explicitly prohibited strikes or walkouts during the pendency of the case. On March 3, 1965, the parties entered into an agreement to submit any further disputes as incidents of the main certified case. Subsequently, Republic Act No. 4180 raised the statutory minimum wage. The union demanded a corresponding wage adjustment for employees already earning above the new minimum, but the company refused to negotiate, contending the matter was connected to the pending certified case. The union filed a notice of strike, prompting the company to seek injunctive relief from the CIR as an incident to the main case, docketed as CIR Case No. 51-IPA(2).

ISSUE

The primary issue is whether the CIR retained jurisdiction to enjoin the threatened strike based on the new wage adjustment demand arising from R.A. No. 4180 , considering the pending certified case and the parties’ prior agreement.

RULING

The Supreme Court affirmed the CIR’s orders, ruling it retained jurisdiction. The legal logic is anchored on the nature of a certified case and the doctrine of absorption. The President’s certification under Section 10 of Republic Act No. 875 vested the CIR with compulsory arbitration powers over the entire dispute, which included the union’s original three-year wage increase demand. The subsequent wage adjustment demand, though triggered by a new law, was intrinsically connected to and absorbed by the already pending wage issue in the certified case. The Court emphasized that once a case is certified, the CIR assumes exclusive jurisdiction to decide all matters related to the dispute, and the parties cannot unilaterally revert to negotiation or strike over connected issues. The March 3, 1965 agreement reinforced this by committing future disputes to the court as incidents. The CIR’s November 9, 1964 order expressly prohibited strikes during the pendency of the case. Therefore, the threatened strike over the new wage adjustment was a violation of that lawful order, and the CIR properly exercised its ancillary power to issue an injunction to maintain the status quo and enforce its authority. The Court also found no denial of procedural due process, as the union was heard through its motions, and the orders were a provisional sanction to secure obedience, not a final adjudication on the merits of the termination of employment.