G.R. No. L-32877 October 30, 1975
FEDERATION OF FREE WORKERS, ET AL., petitioners, vs. HON. LORENZO RELOVA, ET AL., respondents.

FACTS

Petitioner Federation of Free Workers is a legitimate labor organization. The other petitioners were elected officers of the De Dios Dri-Con Association, an affiliate union, in August 1969. Their one-year term was set to expire in August 1970. Among the respondents were union members, including Epitacio Torres, who filed certificates of candidacy for the 1970 elections. However, Torres was expelled from the union in July 1970 for acts inimical to its interest, a matter he challenged before the Court of Industrial Relations (CIR). The union’s Election Committee subsequently disqualified him from running. Upon advice from the Department of Labor and due to the pending CIR case, the union’s Board of Directors postponed the August 1970 election and amended the union’s constitution to extend the incumbent officers’ term to two years.
On September 12, 1970, private respondents, including Torres, proceeded to hold their own election, wherein they were elected as the new set of officers. The company management refused to recognize them and continued to deal with the petitioners. Consequently, the private respondents filed a petition for injunction with the Court of First Instance of Quezon City, seeking to enjoin the incumbent officers from holding over and to compel the company to recognize them as the legitimate officers.

ISSUE

Whether the Court of First Instance has jurisdiction over an intra-union dispute concerning the legitimacy of union officers.

RULING

The Supreme Court ruled that the Court of First Instance had no jurisdiction. The legal logic is anchored on the doctrine of primary jurisdiction. Intra-union disputes, specifically those involving the election of officers and the interpretation of a union’s constitution and by-laws, fall within the exclusive original jurisdiction of the Bureau of Labor Relations (then a part of the Department of Labor) as provided under the Labor Code. The Court emphasized that the determination of which set of officers is legitimate is a matter intricately linked to the internal affairs of the labor organization, requiring the special expertise of the labor agency. Citing Article 226 of the Labor Code, as amended, the Court held that the Bureau has the power to hear and decide any reported violation of the rights and conditions of union membership, including the right to elect officers. Allowing the regular courts to assume jurisdiction would undermine this specialized administrative machinery and potentially lead to conflicting decisions. Therefore, the respondent court should have dismissed the case for lack of jurisdiction. The Supreme Court set aside the lower court’s order, made its temporary injunction permanent, and directed the dismissal of the civil case.