**Philippine Association of Free Labor Unions (PAFLU) vs. Judge Cloribel, Wellington Investment & Manufacturing Corp., and Metropolitan Bank & Trust Company (1966)**
### Facts:
1. **Strike and Picketing:** PAFLU initiated a strike against Metropolitan Bank & Trust Company (METBANK), whose office is on the ground floor of the Wellington Building, Plaza Calderon, Binondo, Manila.
2. **Wellington’s Complaint:** Wellington Investment & Manufacturing Corp., owning the building, complained about picketers obstructing the common passageway, inconveniencing Wellington and other tenants.
3. **Initial Injunction:** Judge Cloribel issued an ex parte order directing PAFLU to cease demonstration and picketing in front of Wellington Building’s common passageway.
4. **Certiorari Petition:** PAFLU filed a petition for certiorari in the Supreme Court, alleging violation of Republic Act No. 875 (Industrial Peace Act) and lack of jurisdiction by Judge Cloribel.
5. **Supreme Court’s Temporary Restraining Order (TRO):** Issued a TRO against Judge Cloribel’s order, later extended, to specifically cover picketing restrictions at the passageway.
6. **Additional Injunction by Judge Cloribel:** A second injunction issued by Judge Cloribel in a related but separate case against the same picketing.
7. **Supplemental Petition:** PAFLU filed a supplemental petition claiming Judge Cloribel violated the Supreme Court’s TRO and renewed injunctions.
### Issues:
1. **Applicability of Republic Act No. 875:** Whether the cases involved a labor dispute and required adherence to specific provisions under the Industrial Peace Act.
2. **Proper Issuance of Injunctions:** Whether the injunctions issued without compliance with procedural requirements (verification, bond filing) were valid.
3. **Legitimacy of Picketing Regulation:** Whether restricting PAFLU’s picketing in the common passageway was justifiable.
### Court’s Decision:
1. **Existence of Labor Dispute (Issue 1):**
– **Court’s Analysis:** The dispute was between PAFLU and METBANK, not involving Wellington or Galang. Hence, the case did not fall within the purview of Section 9 of the Industrial Peace Act.
– **Ruling:** Republic Act No. 875’s provisions were not applicable. The matter was instead governed by Rule 58 (Injunctions) of the Rules of Court.
2. **Issuance of Injunctions (Issue 2):**
– **Court’s Analysis:** The Court found deficiencies in Judge Cloribel’s orders, including failure to require the mandatory bond before issuing preliminary injunctions.
– **Ruling:** The injunctions were annulled due to procedural lapses despite jurisdiction over the subject matter.
3. **Regulation of Picketing (Issue 3):**
– **Court’s Analysis:** While right to picket is constitutionally protected, it can be regulated to protect third parties or “innocent bystanders” with no connection to the labor dispute.
– **Ruling:** Wellington and Galang, being innocent bystanders, had a right to be protected from indirect effects of the picketing.
### Doctrine:
1. **Scope of Labor Disputes:** Labor disputes under Republic Act No. 875 are contingent on a direct employer-employee relationship or substantial connection.
2. **Regulation of Picketing Rights:** Picketing, while an element of free speech, can be locally confined by the court to prevent undue harm to unrelated third parties.
3. **Mandatory Bond for Injunctions:** Injunctions require compliance with all procedural mandates, including bond filing.
### Class Notes:
– **Key Elements:**
– **Labor Dispute:** Direct connection between picketers and party being picketed.
– **Procedural Aspects of Injunction:** Verification, bond requirement, and jurisdiction.
– **Principles Related to Picketing:**
– Not absolute.
– Courts can regulate for third-party protection.
– **Statutory Provisions:**
– **Republic Act No. 875:**
– Section 9 (d): Specific requirements for labor injunctions.
– **Rule 58, Rules of Court:**
– Section 4: Verified complaint and bond requirements.
### Historical Background:
– **Industrial Peace Act Context:** Republc Act No. 875 (enacted in 1953), aimed to minimize industrial conflicts, balancing the right to unionize, collective bargaining, and peaceable picketing against overarching economic interests.
– **Contemporary Labor Movements:** Post-WWII era saw a surge in labor movements emphasizing worker rights against a backdrop of economic rebuilding in the Philippines.
This brief provides a holistic overview of the case’s facts, legal issues, the ruling, established doctrines, class notes for understanding core legal principles, and a historical context in relation to the labor dispute framework during the mid-20th century.
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