G.R. No. L-35126. August 30, 1988.
JACINTO FLORES, et al., petitioners, vs. FILIPINO HAND EMBROIDERY CO., INC. and HON. HERMINIO C. MARINO, respondents.

FACTS

Petitioners are factory workers and officers of the Hand Embroidery Workers Union-CCLU, which sought to bargain with private respondent Filipino Hand Embroidery Co., Inc. The company refused, citing an existing collective bargaining agreement with another union. On May 11, 1971, a petition for certification election was filed with the Court of Industrial Relations (CIR). Subsequently, on May 18, 1971, the company dismissed 43 workers, including petitioners, allegedly for reduced productivity. The union then filed an unfair labor practice (ULP) charge with the CIR on May 19, 1971.
On the same date, May 19, 1971, the company filed a civil case for injunction and damages with the Court of First Instance (CFI) of Rizal, presided by respondent Judge Herminio C. Mariano, alleging that petitioners threatened to blockade the factory premises. The CFI issued a restraining order. Petitioners moved to dismiss for lack of jurisdiction, arguing the dispute fell within the exclusive jurisdiction of the CIR. The CFI denied the motion and later declared petitioners in default.

ISSUE

Whether the Court of First Instance had jurisdiction over the company’s complaint for injunction and damages, or whether jurisdiction was exclusively vested in the Court of Industrial Relations.

RULING

The Supreme Court ruled that the CFI had no jurisdiction. The legal logic is anchored on the doctrine of exclusive jurisdiction over labor disputes and the prohibition against split jurisdiction. The company’s action for damages and injunction arose directly from, and was inextricably intertwined with, the labor dispute involving the pending certification election and the ULP charge already filed with the CIR. The CFI’s own findings in its order explicitly acknowledged the existence of the certification election petition and the ULP charge.
Under the governing laws ( Republic Act No. 875 , since superseded by the Labor Code), the CIR had exclusive jurisdiction over all matters arising from ULP cases and certification elections. To allow a regular court to adjudicate a claim for damages and injunction stemming from the same factual nucleus as the ULP charge would sanction split jurisdiction, leading to conflicting rulings and prejudicing the orderly administration of justice. Consequently, the CFI’s assumption of jurisdiction was a nullity. All its subsequent orders, including the default declaration and the injunction, were declared void ab initio. The writ of preliminary injunction issued by the Supreme Court was made permanent.