G.R. No. L-39084 February 23, 1988
PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU), petitioner, vs. EMILIO V. SALAS, Judge of the Court of First Instance of Rizal, Seventh Judicial District, Branch I, Pasig, Rizal and WONG KING YUEN, respondents.

FACTS

The petitioner, Philippine Association of Free Labor Unions (PAFLU), secured a favorable decision from the Court of Industrial Relations (CIR) in an unfair labor practice case. To execute the judgment, the provincial sheriff levied on personal properties found in the residence of the judgment debtor, Gan Hun. The private respondent, Wong King Yuen, filed a Complaint for damages with the Court of First Instance (CFI) of Rizal against the sheriff, claiming ownership of the levied properties as Gan Hun’s mere boarder. The CFI, presided by respondent Judge Emilio V. Salas, issued a writ of injunction to restrain the sheriff’s sale.
PAFLU intervened in the civil case and moved for its dismissal, asserting that the CFI lacked jurisdiction. It argued that the case related to an existing labor dispute and thus fell under the exclusive jurisdiction of the industrial court. The CFI denied the motion to dismiss and the subsequent motion for reconsideration, prompting PAFLU to elevate the case to the Supreme Court via a petition for certiorari.

ISSUE

Whether or not the Court of First Instance had jurisdiction to take cognizance of and issue an injunctive writ in Civil Case No. 18460, an action for damages filed by Wong King Yuen against the provincial sheriff.

RULING

The Supreme Court ruled in the affirmative, upholding the CFI’s jurisdiction. The legal logic centers on the nature of the action and the parties involved. Civil Case No. 18460 was an ordinary civil action for damages directed against the provincial sheriff, seeking recovery against his official bond under the Rules of Court. The Court emphasized that for the CIR to have jurisdiction under Commonwealth Act No. 103 , there must be a labor dispute—a controversy arising between or affecting employers and employees.
The Court found no such employer-employee relationship or labor dispute between the contending parties in the civil case, PAFLU and Wong King Yuen. The action arose from the sheriff’s execution of a labor judgment, but the claim itself was a proprietary one by a third party alleging wrongful levy. This made the case distinct and separate from the underlying labor dispute pending before the CIR. Consequently, the subject matter of the civil case—determination of ownership and liability for damages from the execution—was within the general jurisdiction of the CFI. The injunction issued was a provisional remedy ancillary to that validly assumed jurisdiction. The Petition for certiorari was dismissed for lack of merit.