G.R. No. L-39741 May 30, 1975
NATION MULTI SERVICE LABOR UNION, ET AL., petitioners, vs. HON. MARIANO V. AGCAOILI, AMBASSADOR HOTEL, INC. and SIMEON NICHOLAS CHAN, respondents.

FACTS

The petitioners, a labor union and its members, filed unfair labor practice cases against the private respondents, Ambassador Hotel, Inc. and its manager. The cases were heard by a compulsory arbitrator under Presidential Decree No. 21, who ruled in favor of the petitioners, declaring the existence of an employer-employee relationship and ordering reinstatement with backwages. Private respondents appealed this decision to the National Labor Relations Commission (NLRC), which affirmed the arbitrator’s finding of employer-employee status. A subsequent appeal to the Secretary of Labor resulted in a resolution dated October 23, 1974, which affirmed the NLRC decision in toto, declaring it final and executory.
Notwithstanding the finality of the Secretary of Labor’s decision, which under P.D. No. 21 was appealable only to the President, private respondents bypassed this administrative remedy. Instead, on October 26, 1974, they filed a petition for certiorari with the Court of First Instance of Manila, presided over by respondent Judge Mariano V. Agcaoili, seeking to nullify the Secretary’s resolution. The CFI issued a temporary restraining order, thereby halting the execution of the final and executory labor order.

ISSUE

Whether the Court of First Instance committed a grave abuse of discretion in assuming jurisdiction over the petition for certiorari and issuing a restraining order against the implementation of a final decision of the Secretary of Labor rendered under P.D. No. 21.

RULING

Yes. The Supreme Court granted the petition for certiorari and prohibition, ruling that the respondent Judge committed a grave abuse of discretion. The legal logic is anchored on the doctrine of exhaustion of administrative remedies and the specific finality provisions of P.D. No. 21. The law provided a clear and exclusive appellate hierarchy: decisions of the Secretary of Labor were appealable only to the President. By filing a judicial action instead of appealing to the President, private respondents disregarded this statutory procedure. The CFI’s assumption of jurisdiction effectively frustrated the speedy and expeditious settlement of labor disputes, which was the fundamental objective of P.D. No. 21. While the Court acknowledged the CFI’s general jurisdiction, its intervention in this case was unwarranted. The private respondents had been afforded ample opportunity to be heard at the arbitration, NLRC, and Secretary of Labor levels. Their claim of denial of procedural due process, based on a lack of notice at the NLRC appeal stage, was insufficient to justify judicial intrusion, especially since they fully participated in the proceedings before the arbitrator and the Secretary. The Supreme Court emphasized that the policy of social justice and protection to labor mandates the final and immediate execution of labor decisions to prevent the dilution of workers’ rights through protracted litigation. Consequently, the CFI’s orders were annulled, and the final decision of the Secretary of Labor was ordered implemented.