GR L 34147; (August, 1985) (Digest)
G.R. No. L-34147. August 28, 1985. TERESITA ALO and FEDERATION OF FREE FARMERS (FFW), petitioners, vs. HON. VALERIO V. ROVIRA, Presiding Judge of the Court of First Instance, Branch IV, Iloilo City, GENOVEVA SO CHAN TOO, SY KIAN TIOK and the PROVINCIAL SHERIFF OF ILOILO, respondents.
FACTS
Petitioner Teresita Alo, a cashier at the Iloilo Shanghai Bazar, organized a union chapter. After the union requested recognition, the store owners, private respondents Genoveva So Chan Too and Sy Kian Tiok, filed a petition for certification election with the Court of Industrial Relations (CIR). Alo was subsequently demoted and then dismissed, which the union alleged was due to her union activities. The Federation of Free Farmers (FFW) filed a notice of strike and an unfair labor practice charge with the CIR. Concurrently, the union commenced picketing in front of the store.
In response, the store owners filed a civil action for damages with the Court of First Instance (CFI) of Iloilo, seeking to enjoin the picketing. The CFI, presided by respondent Judge Valerio V. Rovira, granted a writ of preliminary injunction against the picket. Petitioners Alo and the FFW challenged this CFI order via certiorari, asserting that the CFI lacked jurisdiction as the case involved a labor dispute falling under the exclusive jurisdiction of the CIR.
ISSUE
Whether the Court of First Instance had jurisdiction to entertain the civil action for damages and issue an injunction against the picketing arising from a labor dispute involving an unfair labor practice charge.
RULING
The Supreme Court granted the petition, annulling the CFI’s orders. The Court ruled that the CFI had no jurisdiction over the subject matter. The acts complained of in the civil case for damages were interwoven with the unfair labor practice charge pending before the CIR. Citing Veterans Security Free Workers Union vs. Cloribel, the Court held that labor disputes arising from unfair labor practices are within the exclusive jurisdiction of the CIR, not the CFI. The mere prior filing of the civil action in the CFI did not divest the CIR of its exclusive jurisdiction.
The Court further noted that even under the subsequently enacted Labor Code (P.D. No. 442), which abolished the CIR and vested jurisdiction over all employer-employee relations, including unfair labor practices, in the Labor Arbiters and the National Labor Relations Commission, the regular courts (successors to the CFI) would still lack jurisdiction. Consequently, whether under the law at the time of the dispute or under the prevailing Labor Code, the CFI’s assumption of jurisdiction was a grave abuse of discretion. The injunction orders were declared null and void for lack of jurisdiction.