G.R. No. L-78621 December 2, 1987
SAMAHANG MANGGAGAWA NG LIBERTY COMMERCIAL CENTER ORGANIZED LABOR ASSOCIATION IN LINE INDUSTRIES AND AGRICULTURE (SMLCC-OLALIA), EDITHA BORROMEO, ET AL., petitioners, vs. HON. JUDGE OSCAR B. PIMENTEL, Presiding Judge, Branch 17, Regional Trial Court, Tabaco, Albay, and LIBERTY COMMERCIAL CENTER, respondents.

FACTS

Petitioner labor union filed a petition for direct certification and a notice of strike for alleged union busting and unfair labor practices against private respondent Liberty Commercial Center. The union subsequently staged a peaceful picket at the respondent’s store. In response, the respondent corporation filed a complaint for damages with a prayer for a preliminary mandatory injunction with the Regional Trial Court (RTC) against petitioner Editha Borromeo and others, seeking to disperse the picketing. The petitioners moved to dismiss the complaint on the ground that the RTC lacked jurisdiction over the labor dispute. The respondent court denied the motion, issuing a writ of preliminary injunction against the picketing. The court reasoned that jurisdiction was determined by the allegations in the complaint, which stated the defendants were dismissed or resigned employees and strangers, and that no labor dispute existed at the time of filing since unfair labor practice charges had not yet been proven before the proper forum.

ISSUE

Whether the Regional Trial Court has jurisdiction over the complaint for damages and injunction arising from the picketing activity.

RULING

No. The Supreme Court ruled that the RTC had no jurisdiction. The legal logic is anchored on the exclusive jurisdiction conferred by the Labor Code upon Labor Arbiters over cases arising from labor disputes, including those involving the legality of strikes and lockouts. The Court rejected the respondent court’s view that the absence of a proven unfair labor practice case before the labor tribunal at the time of filing meant no labor dispute existed, thereby vesting jurisdiction in the regular courts. This reasoning, if sustained, would promote conflict of jurisdiction and render meaningless the statutory grant of “original and exclusive jurisdiction” to the labor agencies. The concerted action of picketing, regardless of its alleged illegality, is an act arising from a labor dispute. The proper forum for addressing the legality of the picketing and any incidental claims for damages is the labor relations machinery, not the regular courts. The Court emphasized that this ruling does not condone illegal picketing but insists that such matters be ventilated before the correct forum. The assailed RTC order was annulled and the temporary restraining order was made permanent.