G.R. No. L-30826. April 30, 1974.
NEW FRONTIER SUPERMARKET LABOR UNION, ET AL., petitioners, vs. HON. VICENTE G. ERICTA, Judge of the Court of First Instance of Rizal, Branch XVIII, Quezon City; THE PROGRESSIVE DEVELOPMENT CORPORATION, and THE CITY SHERIFF OF QUEZON CITY, respondents.

FACTS

Petitioner New Frontier Supermarket Labor Union filed unfair labor practice cases with the Court of Industrial Relations (CIR) against New Frontier Supermarket on March 20, 1969, and later issued a notice of strike. A strike and picketing commenced on July 16, 1969, at the three gates of the supermarket building located in Cubao, Quezon City. On July 18, 1969, respondent Progressive Development Corporation, the owner of the business compound where the supermarket building stood, filed a complaint for damages with a prayer for a preliminary injunction against the union and individual petitioners in the Court of First Instance (CFI) of Rizal. It was admitted during hearings that the corporation did not operate any store within the compound, including the supermarket, and that no store owner requested the filing of the suit.
Respondent Judge Vicente G. Ericta, presiding over the CFI, granted the writ of preliminary injunction on July 25, 1969, and issued it the following day. The order broadly enjoined all petitioners from “further acts of picketing, within the property” of the respondent corporation. The union’s motion for reconsideration was denied, prompting this certiorari petition challenging the CFI’s jurisdiction.

ISSUE

Whether the Court of First Instance had jurisdiction to issue a writ of preliminary injunction against picketing arising from a labor dispute where unfair labor practice cases were pending before the Court of Industrial Relations.

RULING

The Supreme Court granted the petition, nullifying the injunction and ordering the dismissal of the civil case for lack of jurisdiction. The legal logic is firmly rooted in the doctrine of exclusive jurisdiction of the Court of Industrial Relations over incidents arising from an unfair labor practice dispute. Once an unfair labor practice case is filed with the CIR, all related matters, including applications for injunction against picketing connected to that dispute, fall within the CIR’s exclusive competence to the exclusion of regular courts.
The Court rejected the respondent judge’s view that jurisdiction vested in the CFI because the suit was filed by the compound owner, not the supermarket management. This distinction was deemed irrelevant. The pivotal factor was the existence of the pending unfair labor practice cases before the CIR, which established that the picketing was an incident of a labor dispute. Citing precedents such as S.M.B. Box Factory Workers Union v. Judge Victoriano and Reyes v. Tan, the Court held that where an element of unfair labor practice is present, the power to issue injunctions rests solely with the CIR under the statutory framework designed to centralize labor dispute resolution.
Furthermore, the Court emphasized the constitutional dimension of picketing as an exercise of free speech. The blanket prohibition against all picketing within the property, absent any showing of violence or coercion exceeding peaceful persuasion, was constitutionally infirm. The CFI’s assumption of jurisdiction and issuance of the overbroad injunction thus constituted a grave abuse of discretion. The policy of the law is to vest labor disputes in the specialized labor court, especially where jurisdiction is doubtful, to ensure consistent and expert adjudication.