G.R. No. L-25171; August 17, 1967
NATIONAL BREWERY AND ALLIED INDUSTRIES LABOR UNION (PAFLU), petitioner, vs. HON. GAUDENCIO CLORIBEL, as Presiding Judge of Branch VI, Court of First Instance of Manila, SAN MIGUEL CORPORATION and THE PHILIPPINE BANKING CORPORATION, respondents.

FACTS

The National Brewery & Allied Industries Labor Union (PAFLU) filed a petition for prohibition with preliminary injunction in the Court of First Instance of Manila (Civil Case No. 56563) against San Miguel Corporation, Philippine Banking Corporation, and Philippine National Bank. The petition alleged that petitioner was the collective bargaining representative of San Miguel Corporation’s workers. An internal union dispute arose from two elections: one on November 7, 1963, where Antonio Santos’s faction was elected, and another on February 19, 1964, where Charles Mitscheck’s faction claimed election. Due to the dispute, the incumbent officers remained as hold-over officers. Under the collective bargaining agreement, San Miguel Corporation deducted union dues from members’ wages for remittance to the union treasurer. Mitscheck notified San Miguel Corporation and the banks of his faction’s election, causing the banks to refuse honoring checks drawn by the Santos faction, thereby paralyzing the union’s financial affairs. The petition sought to restrain the banks from honoring Mitscheck’s claims. The respondent Judge, finding the subject matter involved unfair labor practices under Republic Act No. 875 and that a related case (CIR Case No. 4128) was pending before the Court of Industrial Relations, issued an order on April 25, 1964, holding the case in abeyance until the CIR decided it. The order also required San Miguel Corporation to deposit the deducted union dues with the court. Petitioner challenged this portion of the order requiring the deposit. Subsequently, the two factions agreed to submit their controversy to arbitration before CIR Judge Arsenio I. Martinez, whose decision declared the Santos faction as the lawful officers. While arbitration was pending, petitioner filed the instant petition for certiorari before the Supreme Court.

ISSUE

Whether the respondent Judge acted without or in excess of jurisdiction in ordering the deposit with the Court of First Instance of Manila of the union dues and assessments deducted by San Miguel Corporation, despite his finding that the same question was involved in an unfair labor practice case pending before the Court of Industrial Relations.

RULING

Yes. The Supreme Court set aside the order of April 25, 1964. The Court held that the respondent Judge acted without or in excess of jurisdiction. The main issue involved the determination of the legitimate union officers entitled to receive the dues, a matter constituting an “internal labor organization procedure” under Section 3 of Republic Act No. 875 , which falls within the exclusive jurisdiction of the Court of Industrial Relations. The Court cited previous rulings that cases involving rights, conditions, or membership in a union are within the CIR’s exclusive jurisdiction because that court is in a better position to resolve such labor problems. Since the respondent Judge himself found that the subject matter involved unfair labor practices within the CIR’s jurisdiction and that the same question was pending in CIR Case No. 4128, he could not validly issue an ancillary order (for deposit) in a case over which he effectively declared he had no jurisdiction. The ancillary order could only be issued by the competent court having jurisdiction over the main case.