G.R. No. L-26764 July 25, 1967
BACHRACH TRANSPORTATION COMPANY, INC., petitioner, vs. RURAL TRANSIT SHOP EMPLOYEES ASSOCIATION, ET AL., respondents.

FACTS

Respondent unions went on strike on April 19, 1964. After conciliation failed, the President certified the labor dispute to the Court of Industrial Relations (CIR) on May 19, 1964, docketed as Case 48-IPA. On May 20, 1964, the CIR issued an order directing strikers to return to work and the management to reinstate them under the last terms and conditions, and restraining the company from dismissing any employees without the court’s express authority. After the strikers returned, petitioner began suspending, dismissing, and transferring employees without CIR authority, triggering numerous ancillary petitions. One such case involved Feliciano R. Cruz, a senior employee transferred on July 14, 1966, from the Caloocan main terminal to Bayombong, Nueva Vizcaya, which the union alleged was due to his testimony in a related case on July 13, 1966. The union filed an urgent petition for injunction (Case 48-IPA (46)) to enjoin such transfers. On September 8, 1966, the CIR issued an order enjoining the company from transferring any union member from the main terminal to provincial stations or vice-versa without court authority during the pendency of the main case. The CIR en banc denied the company’s motion for reconsideration on October 10, 1966. Petitioner appealed by certiorari to set aside these orders.

ISSUE

Whether the Court of Industrial Relations had the authority to issue the injunctive order dated September 8, 1966, prohibiting the transfer of employees without its express authority during the pendency of the certified labor dispute.

RULING

Yes. The Supreme Court affirmed the CIR’s orders. The injunctive order was a valid exercise of the CIR’s ancillary powers under Section 10 of the Industrial Peace Act (Republic Act 875). The main case (48-IPA) was certified by the President as a labor dispute in an industry indispensable to the national interest. The CIR’s order was ancillary to this main certified case and intended to prevent further deterioration in the relationship between the parties, thereby aiding in the eventual solution of the labor dispute. The Court cited the doctrine that where an action is ancillary to a main action over which a court has jurisdiction, no independent jurisdiction is needed for the ancillary action. The Court rejected petitioner’s arguments that the order interfered with internal operations and efficiency, stating that the CIR judges are sensible to legitimate representations regarding efficient service and public interest. Furthermore, the powers of the CIR under Section 10 are independent of the conditions for injunction under Section 9(d) of the same Act; the overriding consideration is national interest. The petition for certiorari was denied, and costs were imposed on petitioner.