G.R. No. L-30153 September 13, 1972
PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS and LEGASPI OIL EMPLOYEES ASSOCIATION, petitioners, vs. THE HON. PERFECTO QUICHO, Judge of the Court of First Instance of Albay, 10th Judicial District, Branch I and LEGASPI OIL CO., INC., respondents.

FACTS

Respondent Legaspi Oil Co., Inc. filed a complaint for damages with a prayer for a preliminary injunction in the Court of First Instance of Albay against petitioners PAFLU and its local union. The company alleged that, despite the absence of a collective bargaining agreement or a labor dispute, the unions declared a strike and were picketing its premises through threats and violence, causing daily damages and preventing normal business operations. On the same day, the respondent judge issued an ex parte writ of preliminary injunction restraining the picketing.
Petitioners filed an urgent motion for reconsideration, arguing that a labor dispute and a strike did exist, and an unfair labor practice case was already pending before the Court of Industrial Relations (CIR). They contended that the injunction was void for non-compliance with the strict requirements of Section 9(d) of the Industrial Peace Act ( Republic Act No. 875 ). The respondent court failed to act on the motion promptly, leading petitioners to file this certiorari petition before the Supreme Court, challenging the lower court’s jurisdiction and the validity of the injunction.

ISSUE

Whether the respondent Court of First Instance acted without or in excess of its jurisdiction and with grave abuse of discretion in issuing the writ of preliminary injunction.

RULING

Yes. The Supreme Court granted the petition, made the preliminary injunction permanent, and ordered the dismissal of the civil case. The Court ruled that jurisdiction is determined not merely by the allegations in the complaint but by the nature of the dispute as established by the evidence. The respondent court was duly apprised that the strike and picketing were related to a pending unfair labor practice case before the CIR. Under the doctrine of primary jurisdiction, the CIR has exclusive jurisdiction over cases arising from labor disputes involving unfair labor practices. Therefore, the Court of First Instance had no authority to entertain the case or issue the injunctive writ.
Furthermore, the issuance of the writ of preliminary injunction was void for failure to comply with the mandatory procedural requirements of Section 9(d) of Republic Act No. 875 . This law strictly regulates the issuance of injunctions in labor disputes, requiring specific findings of fact from a hearing, which was not conducted. The respondent judge’s act of issuing the injunction ex parte, based solely on the company’s allegations, constituted a grave abuse of discretion. The Court emphasized that the rules under the Industrial Peace Act, not the general rules on injunction, govern in labor dispute cases to protect the workers’ right to collective action.