G.R. No. L-5694; May 12, 1954
PAMBUJAN SUR UNITED MINE WORKERS, plaintiff-appellant, vs. SAMAR MINING COMPANY, INC., defendant-appellee.

FACTS

The Pambujan Sur United Mine Workers, a registered labor union, filed a complaint in the Court of First Instance of Samar against the Samar Mining Company, Inc. The complaint alleged a breach of their closed-shop collective bargaining agreement. Specifically, the union claimed that the company violated a clause requiring the employer to first consult the union and give it three days to furnish necessary workers before hiring from outside the union. The union sought to compel the company to desist from violating the agreement, to allow the replacement of non-union hires with union members, and to pay damages of P210,000. The defendant mining company moved to dismiss the complaint on the ground that the subject matter—differences regarding conditions of employment—was within the exclusive jurisdiction of the Court of Industrial Relations. The Court of First Instance of Samar, through Judge Emilio Benitez, granted the motion to dismiss, prompting the union’s appeal.

ISSUE

The primary issue is whether the jurisdiction of the Court of Industrial Relations over certain controversies between employer and employees is exclusive of the regular courts of justice. This involves two inquiries: (a) whether the subject-matter of the complaint (breach of the collective bargaining agreement) is cognizable by the Court of Industrial Relations, and (b) if so, whether such jurisdiction is exclusive or merely concurrent.

RULING

The Supreme Court affirmed the order of dismissal, holding that the Court of Industrial Relations has exclusive jurisdiction over the dispute.
1. On Cognizability by the Court of Industrial Relations: The dispute falls within the broad jurisdiction of the Court of Industrial Relations under Commonwealth Act No. 103. The collective bargaining contract embodied terms and conditions of employment, including wages, compensation, leave, and the closed-shop clause. The alleged breach constituted an industrial dispute (mining being an industry) arising from differences regarding “conditions of employment” and potentially involving “dismissals” (as the union sought to replace non-union workers). The dispute involved more than thirty employees (the union had 350 member-employees), and bitterness was likely to ensue, potentially leading to a strike, thus invoking the Court’s duty to assume cognizance under Section 4 of Commonwealth Act No. 103. The demand for damages, representing lost wages, did not remove the case from the Industrial Court’s jurisdiction, as it had authority to award such equitable relief.
2. On Exclusivity of Jurisdiction: The jurisdiction of the Court of Industrial Relations over such disputes is exclusive. Although Commonwealth Act No. 103 did not explicitly state exclusivity, it was clearly implied. The Act granted the Court special powers (e.g., to delegate investigations, enforce orders by contempt, act without strict technicalities) particularly adapted for the speedy and equitable settlement of industrial disputes, indicating a legislative intent to centralize such matters in a specialized tribunal. This construction was confirmed by Republic Act No. 875 (the Industrial Peace Act), which expressly provided that the Court’s jurisdiction “shall be exclusive” over matters including unfair labor practices and disputes involving collective bargaining agreements. Therefore, the regular courts, like the Court of First Instance of Samar, lacked jurisdiction to entertain the complaint.