BCI EMPLOYEES AND WORKERS UNION (PAFLU), PETITIONER, VS. HON. PIO MARCOS AND BENGUET CONSOLIDATES INC., RESPONDENTS.

BCI Employees and Workers Union versus Marcos

The Case

This is a petition for certiorari brought by the BCI Employees and Workers Union, a labor organization affiliated with the Philippine Association of Free Labor Unions, against Judge Pio Marcos and Benguet Consolidated, Incorporated. The union asks the Supreme Court to undo a preliminary injunction issued by the Court of First Instance of Baguio, which restrained the union's picketing during a strike. The real question is one of jurisdiction: may a regular trial court, at the instance of the employer, enjoin picketing that grows out of a labor dispute already pending before the Court of Industrial Relations? The case matters because it draws the boundary between the regular courts and the labor court, and it holds that where a labor dispute is already before the industrial court, the regular courts must stay their hand, even when violence is alleged.

Procedural History

The union filed a notice of strike with the Department of Labor, and the company simultaneously filed a notice of lockout. Conciliation conferences failed. The union then struck in the mining areas of Acupan, Antamok and Balatok, and picketing followed. The company went to the Court of First Instance of Baguio, seeking a preliminary injunction against the picketing, to be made permanent later. The union moved to dismiss on two grounds: that the strike arose from unfair labor practice acts already pending before the Court of Industrial Relations, and that the petition failed to comply with the jurisdictional requirements of Section 9, paragraph d, of Republic Act 875. After a hearing, the trial court denied the motion. It later issued the preliminary injunction. The union then came to the Supreme Court on certiorari with preliminary injunction, which the Court granted. The sole issue litigated was the jurisdiction of the Court of First Instance.

Facts

The union was composed of rank and file workers of Benguet Consolidated, Incorporated. On the twenty eighth of December, 1962, it filed a notice of strike with the Department of Labor, and at the same time the company filed a notice of lockout. Conciliation conferences were held but brought no settlement.

On the third of March, 1963, the union declared a strike in the company's three mining areas, all in Itogon, Benguet, Mountain Province. Picketing followed in those areas. Alleging that the strikers were unlawfully picketing the company premises, the company filed a petition in the Court of First Instance of Baguio to restrain the picketing by preliminary injunction, to be made permanent later.

Unknown to the surface of the complaint, the same labor dispute was already the subject of two unfair labor practice cases pending between the same parties before the Court of Industrial Relations. One had been instituted in June 1960, about two and a half years before; the other in August 1962, about four months before the notice of strike. Those cases were based on alleged dismissals of union members without just cause, done because of union affiliation or activities. The strike itself expressly listed, among its reasons, discrimination against union members in the enforcement of disciplinary actions.

Issues

• Whether or not the Court of First Instance of Baguio had jurisdiction to entertain the company's petition to enjoin the picketing, when the labor dispute involved was already pending before the Court of Industrial Relations in unfair labor practice cases.
• Whether or not the regular court may act even if the petition alleges acts of violence, intimidation and coercion on the part of the strikers.

Applicable Provisions

Section 5, paragraph a, of Republic Act 875, the Industrial Peace Act, provides:

The Court of Industrial Relations shall have jurisdiction over unfair labor practice cases, and its jurisdiction over such cases shall be exclusive of all other courts.

This is the provision the Court invokes to hold that the industrial court's jurisdiction over the unfair labor practice cases is exclusive, and that the regular court cannot intrude upon the same labor dispute.

Ruling

On the first issue, the Court held that the Court of First Instance had no jurisdiction. From the very allegations of the company's petition, the action was precipitated by a strike and the consequent picketing, arising from a labor dispute. That labor dispute was already involved in two unfair labor practice cases pending before the Court of Industrial Relations, instituted well ahead of the petition. The same labor dispute was involved in all the cases. The Court therefore concluded that the Court of Industrial Relations had already acquired jurisdiction over the labor dispute when the petition before the Court of First Instance was instituted, and that jurisdiction is exclusive. Since the issues in the action before the respondent judge were interwoven with the unfair labor practice cases, the action was outside the jurisdiction of the regular courts.

On the second issue, the Court held that the rule stands even if the petition avers acts of violence, intimidation and coercion. Such a rule is necessary to avoid multiplicity of suits. If the purpose of the action is to obtain injunctive relief against certain acts of violence of the laborers, the same relief can be obtained from the industrial court, which is given ample powers to act by Republic Act 875.

Doctrine

First, the Court of Industrial Relations has exclusive jurisdiction over unfair labor practice cases, and once it has acquired jurisdiction over a labor dispute, a regular court may not entertain an action whose issues are interwoven with that dispute. Second, the regular court's lack of jurisdiction holds even where the employer's petition alleges violence, intimidation and coercion, because the industrial court has ample powers to grant injunctive relief against such acts. Third, the rule rests on the policy against multiplicity of suits. A bar candidate should tie these rules to Section 5, paragraph a, of Republic Act 875, which makes the industrial court's jurisdiction exclusive.

Disposition

The Supreme Court granted the petition for certiorari, declared the respondent judge without jurisdiction to act in the injunction case, and made the injunction it had earlier issued permanent, with costs against Benguet Consolidated, Incorporated.

Remember This

Memorize this line: once a labor dispute is pending before the Court of Industrial Relations, the regular courts lose jurisdiction over any action whose issues are interwoven with it, even if violence is alleged. Examiners use this case to test the exclusive jurisdiction of the labor court under Republic Act 875 and the rule against multiplicity of suits.