G.R. No. L-26508 October 22, 1975
PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), ET AL., petitioners, vs. HON. WALFRIDO DE LOS ANGELES, and MANLAPAZ PUBLISHING COMPANY, INC., respondents.

FACTS

The Manlapaz Publishing Employees Union, affiliated with PAFLU, declared a strike against the Manlapaz Publishing Company on August 14, 1966. The company responded by filing a petition with the Court of Industrial Relations (CIR) to declare the strike illegal (Case No. 199-INJ). The CIR, finding the petition to involve allegations of unfair labor practice, endorsed it for investigation. Subsequently, the union filed an unfair labor practice charge against the company for refusal to bargain (Charge No. 1323 ULP). While these cases were pending before the CIR, the company filed a separate complaint for damages with a prayer for a preliminary injunction before the Court of First Instance of Rizal, presided by respondent Judge Walfrido de los Angeles. The civil complaint alleged that union members, through force and intimidation, blocked the company’s entrances, causing financial damages.
The union opposed the civil court’s jurisdiction, arguing that the matter involved a labor dispute arising from unfair labor practices, which fell under the exclusive jurisdiction of the CIR. Despite this opposition, respondent Judge issued a restraining order on September 5, 1966, directing the parties to maintain the status quo and specifically restraining the union from blocking the company’s entrances. The union then filed the instant petition for certiorari and prohibition with the Supreme Court, seeking to nullify the restraining order and to halt the civil proceedings for lack of jurisdiction.

ISSUE

Whether the Court of First Instance of Rizal acted without or in excess of its jurisdiction in taking cognizance of the complaint for damages and in issuing the restraining order, considering the pendency of related labor disputes before the Court of Industrial Relations.

RULING

Yes, the respondent Court of First Instance acted without jurisdiction. The Supreme Court granted the writs of certiorari and prohibition, making the preliminary injunction it had issued permanent and directing the dismissal of the civil case. The legal logic is anchored on the doctrine of exclusive jurisdiction over labor disputes. The complaint for damages filed in the civil court was not a simple money claim but was intrinsically interwoven with the labor dispute. The allegations of blocking entrances and causing business losses arose directly from the strike activity, which was the very subject of the pending cases before the CIR involving the strike’s legality and unfair labor practices.
The Court reiterated the established principle that when an unfair labor practice is involved in or attached to an action, the case falls within the exclusive jurisdiction of the labor relations tribunal (then the CIR, now the Labor Arbiters under the Labor Code). The civil court cannot assume jurisdiction by the mere expedient of styling the action as one for damages. To hold otherwise would allow circumvention of the labor relations system designed for the expeditious settlement of such disputes. The fact that the parties later entered into a strike settlement agreement did not render the petition moot, as the core issue of jurisdictional error by the lower court remained. The Supreme Court emphasized that the policy of the law is to centralize the adjudication of labor disputes in specialized bodies to ensure speedy resolution unencumbered by technical procedural strictures.