G.R. No. L-25059 August 30, 1968
FEDERACION OBRERA DE LA INDUSTRIA TABAQUERA Y OTROS TRABAJADORES DE FILIPINAS (FOITAF), petitioner, vs. THE HON. ANGEL MOJICA and LIWAYWAY GAWGAW and COFFEE REPACKING, respondents.

FACTS

Respondent Judge Angel Mojica assumed jurisdiction over a complaint for damages with a writ of preliminary injunction filed by respondent Liwayway Gawgaw & Coffee Repacking on July 12, 1965. The complaint, on its face, did not indicate it involved an unfair labor practice. The respondent Judge granted the preliminary injunction on July 16, 1965. The petitioner, Federacion Obrera de la Industria Tabaquera, filed a motion to dismiss the complaint and to quash the writ, and an answer, both dated July 19, 1965, informing the court of two pending unfair labor practice cases before the Court of Industrial Relations (CIR). The respondent Judge denied the motion to dismiss and to dissolve the writ in an order dated August 28, 1965, stating the court had jurisdiction based on the complaint’s averments. The petitioner then filed this petition for certiorari and prohibition. In its opposition to the motion to dismiss, respondent Liwayway Gawgaw & Coffee Repacking admitted the cases before the CIR were “charges” pending preliminary investigation by CIR prosecutors, not yet before the Court itself.

ISSUE

Whether the respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion, in taking cognizance of the complaint for damages and issuing the preliminary injunction, considering the matter involved an unfair labor practice.

RULING

Yes. The Supreme Court granted the petition. It held that under the Industrial Peace Act, unfair labor practice cases fall within the exclusive jurisdiction of the Court of Industrial Relations. This doctrine is constant and uninterrupted from PAFLU v. Tan to Philippine Communications, Electronics & Electricity Workers’ Federation v. Nolasco. The Court emphasized that the CIR’s jurisdiction is exclusive even if no formal unfair labor practice case has been filed with the CIR; it is enough that an unfair labor practice is involved. The admission by the respondent company that there were charges pending preliminary investigation before the CIR prosecutors was fatal to the lower court’s assumption of jurisdiction. Following the precedent set in Erlanger & Galinger, Inc. v. Erlanger & Galinger Employees Association, a court of first instance has no jurisdiction to issue a restraining order if it is shown that the labor dispute arose from unfair labor practices, regardless of whether a case has been formally filed with the CIR. Therefore, the respondent Judge acted without jurisdiction. The Supreme Court annulled the orders dated July 16, 1965, and August 28, 1965, and ordered the respondent Judge to desist from further action in the civil case.