G.R. No. L-31152 March 27, 1974
University of Nueva Caceres, Jaime Hernandez, Sr., and Jaime Hernandez, Jr., petitioners, vs. Hon. Arsenio I. Martinez, as Presiding Judge of the Court of Industrial Relations, and the University of Nueva Caceres Guardians Union, respondents.

FACTS

On June 17, 1969, respondent University of Nueva Caceres Guardians Union filed an unfair labor practice charge against petitioners with the Bicol branch of the Court of Industrial Relations (CIR). Petitioners moved to dismiss the charge before the CIR prosecutor, citing fatal defects: lack of verification, failure to specify the violated statutory provision, and alleged falsities in the supporting affidavit. The prosecutor, while finding the grounds plausible, did not dismiss the charge. Instead, he granted the Union five days to file an amended charge and affidavit, which it did on July 8, 1969.
Petitioners moved for reconsideration of the prosecutor’s ruling. Respondent Presiding Judge Arsenio I. Martinez, acting alone, denied the motion on July 30, 1969, admitted the amended charge, and directed a preliminary investigation. Petitioners filed another motion for reconsideration, assuming it would be acted upon by the CIR en banc. However, on October 6, 1969, respondent Judge issued an order, signed solely by him, denying the motion. This prompted the present petition, alleging that the Judge acted in excess of jurisdiction by deciding a matter within the authority of the CIR en banc and with grave abuse of discretion in not dismissing the defective charge.

ISSUE

Whether the Presiding Judge of the CIR, acting alone, has the exclusive authority to resolve a motion to dismiss an unfair labor practice charge based on formal defects, or whether such authority resides in the CIR en banc.

RULING

The Supreme Court ruled that the authority to resolve such a motion lies with the CIR en banc, not with the Presiding Judge alone. The legal logic centers on the judicial nature of the preliminary investigation process in unfair labor practice cases under the Industrial Peace Act ( Republic Act No. 875 ). Section 5(b) of the Act confers the investigatory function upon “the Court or any agency or agent designated by the Court.” The Court emphasized that this function is judicial, not administrative. It is analogous to preliminary investigations conducted by courts of first instance in election cases or under the Anti-Subversion Act, which are undeniably judicial proceedings.
The Court rejected the respondent Judge’s theory that overseeing the Prosecution Division’s filing or dismissal of charges is a purely administrative function within his exclusive competence. While the Presiding Judge may have exclusive administrative authority over certain internal matters, the determination of whether a charge suffers from fatal defects is a judicial act. The law allows the CIR to delegate the investigation to an agent, but this does not transform the court’s ultimate responsibility into an administrative one. The delegated agent acts on behalf of the court, and the court retains final authority. Consequently, the orders dated July 30, 1969, and October 6, 1969, issued solely by the Presiding Judge, were set aside. The matter was ordered to be submitted to the CIR en banc for appropriate action.