G.R. No. L-56431. January 19, 1988.
NATIONAL UNION OF BANK EMPLOYEES, et al., petitioners, vs. THE HON. JUDGE ALFREDO M. LAZARO, CFI-MANILA BRANCH XXXV, et al., respondents.

FACTS

Petitioners, the National Union of Bank Employees and the CBTC Employees Union, were parties to a collective bargaining agreement (CBA) with the Commercial Bank and Trust Company (CBTC), effective until June 30, 1980, with an automatic renewal clause. On May 20, 1980, the unions submitted proposals for a new CBA. The following day, CBTC suspended negotiations. It was subsequently revealed that CBTC had entered into a merger with the Bank of the Philippine Islands (BPI), which assumed all its assets and liabilities. The unions filed a complaint in the Court of First Instance for specific performance, damages, and injunction against CBTC, BPI, and their officers. The complaint alleged that the respondents, through secret negotiations and the suspension of CBA talks, acted in bad faith to avoid fresh contractual commitments, thereby violating the CBA and Articles 21 and 28 of the Civil Code, and causing willful injury to the unions’ contract rights.

ISSUE

Whether or not the regular courts have jurisdiction over the complaint for damages arising from the alleged bad faith suspension of collective bargaining negotiations and the consequent merger, or whether jurisdiction lies with the labor arbiters.

RULING

The Supreme Court sustained the dismissal of the case by the lower court, ruling that jurisdiction is vested in the labor arbiters. The complaint, though couched in terms of tort and damages under the Civil Code, essentially alleges an unfair labor practice. The core allegation is that the employer, CBTC, violated its duty to bargain collectively in good faith, and that BPI induced this violation in the context of a merger. This constitutes an unfair labor practice under Article 248(g) of the Labor Code (violation of the duty to bargain collectively). The claim for damages is merely the civil aspect of this unfair labor practice. Pursuant to Article 247 of the Labor Code, as amended, the civil aspects of all cases involving unfair labor practices, including claims for damages, are under the exclusive jurisdiction of the labor arbiters. The Court cited precedents establishing that where the claim for damages is intertwined with a labor dispute, jurisdiction rests with the labor tribunal, not the regular courts. The fact that BPI was not the direct employer at the time is immaterial, as it assumed all liabilities of CBTC upon the merger under the Corporation Code. The respondent judge did not commit grave abuse of discretion in dismissing the case for lack of jurisdiction.