G.R. No. L-25878; March 28, 1969
PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), petitioner, vs. JUDGE GAUDENCIO CLORIBEL OF THE COURT OF FIRST INSTANCE OF MANILA; WELLINGTON INVESTMENT and MANUFACTURING CORPORATION; and METROPOLITAN BANK and TRUST COMPANY, respondents.

FACTS

The Philippine Association of Free Labor Unions (PAFLU) and its members were picketing the Metropolitan Bank and Trust Company (METBANK), located on the ground floor of the Wellington Building owned by Wellington Investment and Manufacturing Corporation. Wellington filed a complaint (Civil Case No. 64831) in the Court of First Instance of Manila, alleging that the picketers were blocking the common passageway of the building, which was the only ingress and egress for occupants of the upper floors and their clients, causing damage and embarrassment. Wellington sought an injunction. Respondent Judge Gaudencio Cloribel issued an ex parte order directing PAFLU to cease and desist from picketing the common passageway. PAFLU filed a petition for certiorari with the Supreme Court, arguing that the judge acted without jurisdiction and with grave abuse of discretion for violating the strict requirements of Section 9 of Republic Act No. 875 (the Industrial Peace Act) on labor injunctions, as the complaint lacked the necessary allegations and a bond. Subsequently, in a separate but identical case (Civil Case No. 64909) filed by another tenant, Emmanuel T. Galang, Judge Cloribel issued another ex parte injunction. PAFLU filed a supplemental petition protesting this second injunction.

ISSUE

Whether the cases before the lower court (Civil Cases Nos. 64831 and 64909) involve or grow out of a labor dispute, thereby making the restrictive provisions of Section 9 of Republic Act No. 875 applicable to the issuance of the injunctions.

RULING

No. The Supreme Court ruled that the cases did not involve a labor dispute between PAFLU and the complainants, Wellington and Galang. The strike and picket were directed solely against METBANK. The relationship between Wellington/Galang and METBANK was merely that of landlord and tenant/co-lessee, which was too remote to constitute a labor dispute under the law. Since no labor dispute existed between the immediate parties, Section 9 of Republic Act No. 875 did not apply. The applicable law was Rule 58 of the Rules of Court on injunction. However, the Supreme Court found that the injunctions were issued ex parte without the complainants filing the necessary bond as required by Section 4 of Rule 58. This omission constituted a grave abuse of discretion. Consequently, the Court granted certiorari and annulled the two preliminary injunctions issued by Judge Cloribel, without prejudice to the right of Wellington and Galang to secure new injunctions after filing the requisite bonds.