G.R. No. L-26358. June 27, 1975. DONATO LOPEZ, JR., petitioner, vs. THE COURT OF FIRST INSTANCE OF MANILA and GENARO C. BAUTISTA, respondents.
FACTS

Petitioner Donato Lopez, Jr. was elected president of the KKMK-NWSA (PAFLU), a labor union of National Waterworks and Sewerage Authority employees. However, private respondent Genaro C. Bautista, a rival candidate, filed a civil action before the Court of First Instance (CFI) of Manila, contesting the election. The CFI, through Judge Francisco Geronimo, issued an ex parte preliminary injunction preventing Lopez from assuming office. Lopez moved to dissolve the injunction and dismiss the case, arguing that the CFI lacked jurisdiction over the intra-union dispute. He contended that jurisdiction was vested exclusively in the Court of Industrial Relations (CIR) under the Industrial Peace Act. The CFI, through subsequent judges, denied his motion and motion for reconsideration, firmly asserting its jurisdiction over the matter.

ISSUE

Whether the Court of First Instance had jurisdiction over a suit involving the election and right to the presidency of a labor union, or whether such dispute fell within the exclusive jurisdiction of the Court of Industrial Relations under the governing labor law.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. The legal logic is anchored on the statutory jurisdiction of the Court of Industrial Relations. The applicable law was Section 17 of the Industrial Peace Act ( Republic Act No. 875 ), which governed rights and conditions of membership in labor organizations, including the election of officers. Jurisprudence had consistently held that intramural disputes, including questions over union elections and officer qualifications, were within the exclusive competence of the CIR, not regular courts. The Court cited Kapisanan ng mga Manggagawa v. Bugnay (1957) and the directly pertinent Phil. Land-Air-Sea Labor Union v. Ortiz (1958), which explicitly stated that cases involving membership rights and internal union affairs fell under CIR jurisdiction because that specialized court was in a better position to handle complex labor-management and intra-union issues. This doctrine was reaffirmed in Philippine Association of Free Labor Unions v. Padilla (1959). Therefore, the CFI’s assumption of jurisdiction was a grave abuse of discretion. The Supreme Court granted the writs of certiorari and prohibition, annulling the CFI’s orders and perpetually restraining it from further proceedings in the case except to dismiss it.