FEDERATION OF FREE FARMERS, JEREMIAS U. MONTEMAYOR, EDGARDO M. VIRIÑA, AND FAUSTINO F. BONIFACIO, JR., PETITIONERS, VS. HON. VICENTE G. ERICTA, AS PRESIDING JUDGE OF THE COURT O…

Federation of Free Farmers versus Ericta

The Case

This is a special civil action for certiorari and prohibition brought by the Federation of Free Farmers and its officers, Jeremias Montemayor, Edgar Viriña, and Faustino Bonifacio, Junior, against Judge Vicente Ericta of the Court of First Instance of Quezon City. The petitioners ask the Supreme Court to annul the judge's refusal to dismiss a quo warranto and damages suit filed against them by a rival faction within the union, on the ground that the dispute is an intra-union matter falling within the exclusive jurisdiction of the labor tribunal and not of the regular courts. The case matters because it fixes the dividing line between courts of general jurisdiction and labor administrative bodies over internal union conflicts, and because it settles that a claim for damages cannot be used to drag such a conflict into the regular courts.

Procedural History

Private respondents, led by Manuel Mondejar, Junior, filed an action for quo warranto and damages with a prayer for preliminary injunction in the Court of First Instance of Quezon City, presided over by Judge Ericta. The judge issued a restraining order against petitioner Montemayor, effective only until November 20, 1973. The petitioners then filed a motion to dismiss on the ground of lack of jurisdiction, and the judge denied it in an order dated March 28, 1974, reasoning that the claim for moral damages removed the case from the competence of the Court of Industrial Relations. A motion for reconsideration was denied on June 10, 1974. The petitioners then went directly to the Supreme Court by a petition for certiorari and prohibition, and the Court granted the relief prayed for.

Facts

The case arose from a dispute within the Federation of Free Farmers between the faction of its President, Jeremias Montemayor, and another faction apparently led by Manuel Mondejar, Junior. On October 18, 1973, the Mondejar group filed a quo warranto and damages suit in the Quezon City Court of First Instance against Montemayor, Viriña, and Bonifacio.

Two days later, Judge Ericta issued a restraining order directing Montemayor to desist from calling a national convention set for October 20, 1973, or on any other date, but the order was valid only until November 20, 1973. Montemayor promptly filed a manifestation informing the court that the convention had already been adjourned, so there was nothing left to restrain.

On October 30, 1973, the petitioners moved to dismiss, arguing that the complaint on its face alleged violations of the rights and conditions of membership in a labor organization and of internal labor organization procedures. Judge Ericta denied the motion only on March 28, 1974, relying on the claim for moral damages and citing Montemayor's own work on labor legislation to conclude that the Court of Industrial Relations had no jurisdiction. Reconsideration was denied, and the petitioners came to the Supreme Court.

Issues

• Whether or not the Court of First Instance has jurisdiction over an action for quo warranto arising from an intra-union dispute involving the rights and conditions of membership in a labor organization.
• Whether or not the claim for damages in the complaint converts the dispute into an ordinary civil action cognizable by the regular courts.

Applicable Provisions

Section 17 of the Industrial Peace Act, Republic Act Number 875, provides:

It is hereby declared to be the public policy of the Philippines to encourage the following internal labor organization procedures. A minimum of ten percent of the members of a labor organization may report an alleged violation of these procedures in their labor organization to the Court. If the Court finds, upon investigation, evidence to substantiate the alleged violation and that efforts to correct the alleged violation through the procedures provided by the labor organization's constitution or by-laws have been exhausted, the Court shall dispose of the complaint as in unfair labor practice cases.

This is the provision that vested the Court of Industrial Relations, the Court referred to in the text, with jurisdiction over violations of internal labor organization procedures, and it is the basis for holding that the regular court had no power over the suit.

Article 225 of Presidential Decree Number 570 provides:

Bureau of Labor Relations. The Bureau of Labor Relations and the labor relations divisions in the regional offices of the Department of Labor shall have original and exclusive authority to act, at their own initiative or upon request of either or both parties, on all inter-union and intra-union conflicts, and all disputes, grievances or problems arising from or affecting labor-management relations in all workplaces whether agricultural or non-agricultural, except those arising from the implementation or interpretation of collective bargaining agreements which shall be the subject of grievance procedure and or voluntary arbitration.

This provision identifies the body that replaced the Court of Industrial Relations over intra-union conflicts, and it tells the private respondents where their remedy, if any, now lies.

Ruling

On the first issue, the Court ruled that the respondent judge was devoid of jurisdiction. It relied on a long line of decisions holding that questions involving the rights and conditions of membership in a labor organization fall within the jurisdiction of the Court of Industrial Relations, which is better qualified than ordinary courts to resolve them. The Court quoted with approval the ruling that the court vested with jurisdiction over violations of internal labor organization procedures is the Court of Industrial Relations, and that the lower court therefore correctly dismissed the complaint.

On the second issue, the Court held that the claim for damages did not convert the case into an ordinary tort action. Whether damages are recoverable, and to what extent, would still depend on the resolution of the very question of whether the union's constitution and by-laws were violated and which set of officers has the right to represent the union, questions conferred by law upon administrative bodies. The Court quoted the controlling doctrine:

Nor will Sugeco's averment below that it suffers damages by reason of the strike, work to defeat the CIR's jurisdiction to hear the unfair labor practice charge. Reason for this is that the right to damages would still have to depend on the evidence in the unfair labor practice case in the CIR. To hold otherwise is to sanction split jurisdiction which is obnoxious to the orderly administration of justice.

The Court clarified that its ruling extends only to the lack of jurisdiction of the respondent judge, and that whatever remedy remains to the private respondents should be sought elsewhere, since the Court of Industrial Relations has now been replaced by the Bureau of Labor Relations insofar as intra-union conflicts are concerned.

Doctrine

First, intra-union disputes involving the rights and conditions of membership in a labor organization, including quo warranto actions over union office, fall within the exclusive jurisdiction of the labor tribunal and not of the regular courts. Second, a claim for damages does not defeat that jurisdiction, because the right to damages depends on the resolution of the labor question, and to hold otherwise would sanction split jurisdiction, which is obnoxious to the orderly administration of justice. Third, the ruling reaches only the question of jurisdiction, leaving the parties free to pursue their remedy before the proper labor body, now the Bureau of Labor Relations under Article 225 of Presidential Decree Number 570.

Disposition

The Supreme Court granted the writ of certiorari, nullified the orders denying the motion to dismiss and the motion for reconsideration, and granted the writ of prohibition perpetually restraining the successor of Judge Ericta from acting on the complaint except to dismiss it, without costs.

Remember This

Memorize the line that intra-union disputes belong to the labor tribunal, and that a claim for damages cannot be used to split jurisdiction. Examiners use this case to test jurisdiction over intra-union conflicts and the rule against split jurisdiction.