KAISAHAN NG MGA MANGGAGAWA SA LA CAMPANA (KKM), PETITIONER, VS. HON. HERMOGENES CALUAG, ETC. ET AL., RESPONDENTS.

Kaisahan ng mga Manggagawa sa La Campana versus Caluag

The Case

This is an original action for certiorari and prohibition brought by the Kaisahan ng mga Manggagawa sa La Campana, the labor union, against Judge Hermogenes Caluag of the Court of First Instance of Quezon City and the private respondents, to have the respondent judge declared without jurisdiction to try, hear, and decide a civil case for prohibition that had been filed before him. The union had won a final and executory order from the Court of Industrial Relations in its favor, and the private respondents went to the Court of First Instance to stop that order from being enforced. The case matters because it fixes a clean rule on the hierarchy of courts: a court cannot issue the extraordinary writs of injunction and prohibition against a tribunal of equal rank. It is a staple in remedial law and in labor law, where the Court of Industrial Relations once stood side by side with the Courts of First Instance.

Procedural History

The story begins in the Court of Industrial Relations, which issued a final order in favor of the union in a labor case. When that order became executory, the union moved for a writ of execution, and the Court of Industrial Relations issued the writ, directing the administrator of the estate and the factory to reinstate the named workers and to deposit the amount of 65,534 pesos and one centavo to pay their back wages. The parties failed to comply, so a motion for contempt was filed. Ricardo Tantongco then went to the Supreme Court on a petition for certiorari and prohibition to restrain the Court of Industrial Relations and the union from proceeding on the contempt charge, but that petition was denied. A second writ of execution was later issued by the acting clerk of the Court of Industrial Relations. As the sheriff of Quezon City was about to enforce it, Ricardo Tantongco and La Campana Food Products, Incorporated, filed an action for prohibition with a prayer for preliminary injunction in the Court of First Instance of Quezon City, presided over by the respondent judge. The union moved to dismiss on the ground of lack of jurisdiction over the subject matter, but the respondent judge ordered the union to file an answer, which it did. The union then came to the Supreme Court by this original action for certiorari and prohibition.

Facts

The Court of Industrial Relations had issued a final order in a labor dispute between the union and La Campana Starch and Coffee Factory, together with the administrator of the estate of the deceased Ramon Tantongco. The order became executory, and upon motion the Court of Industrial Relations issued a writ of execution directing reinstatement of the workers named in the order and the deposit of 65,534 pesos and one centavo for their back wages.

When the respondents failed to comply, the union moved for contempt. Ricardo Tantongco tried to stop the contempt proceedings by a petition for certiorari and prohibition in the Supreme Court, but the petition was denied. A second writ of execution was then issued by the acting clerk of the Court of Industrial Relations.

On the eve of enforcement by the sheriff of Quezon City, Ricardo Tantongco and La Campana Food Products, Incorporated, filed a prohibition case in the Court of First Instance of Quezon City to nullify the writ and to restrain the Court of Industrial Relations and its acting clerk from enforcing it, and to recover damages. The union challenged the jurisdiction of that court, but the respondent judge proceeded and required an answer. Hence this original action.

Issues

• Whether or not the Court of First Instance of Quezon City has jurisdiction over the subject matter of a prohibition case whose purpose is to nullify a writ of execution issued by the Court of Industrial Relations and to restrain that court and its acting clerk from enforcing it.
• Whether or not a Court of First Instance may issue a writ of preliminary injunction or a writ of prohibition against the Court of Industrial Relations.

Applicable Provisions

The decision does not quote any statutory text; it rests on the settled rule on the rank of courts and on the nature of the writs of injunction and prohibition. The governing principle, as the Court states it, is that these writs may issue only from a court to a tribunal or officer lower in rank. The Court expresses the rule in these words:

Such being the case, it is obvious that the Court of First Instance presided by the respondent judge cannot issue a writ of preliminary injunction nor a writ of prohibition against the Court of Industrial Relations, because said writs may be issued only by a court to another tribunal or officer exercising either judicial or ministerial functions, lower in rank.

This principle bears directly on the case because the relief prayed for in the prohibition case was precisely an injunction and a prohibition against the Court of Industrial Relations, a tribunal of equal rank with the Court of First Instance.

Ruling

On the first issue, the Court ruled that the respondent court has no jurisdiction over the subject matter. It held that the Court of Industrial Relations is equal in rank with the Courts of First Instance, and that this equality of rank removes the case from the jurisdiction of the Court of First Instance. The purpose of the amended petition for prohibition was to secure a judgment nullifying the writ of execution issued by the acting clerk of the Court of Industrial Relations, to restrain or prohibit that court and its acting clerk from enforcing the writ, and to recover damages. Since the target of the action was a tribunal of equal rank, the Court of First Instance could not take cognizance of it.

On the second issue, the Court ruled that the writs of preliminary injunction and prohibition cannot issue against the Court of Industrial Relations. The Court stated the rule in the passage quoted above: such writs may be issued only by a court to another tribunal or officer exercising judicial or ministerial functions, lower in rank. Because the Court of Industrial Relations is not lower in rank than the Court of First Instance, the writs could not be directed against it. The Court granted the writ, without costs, and without prejudice to the filing of an ordinary action for the recovery of the damages allegedly suffered by the respondents, with the exception of the respondent judge.

Doctrine

First, the Court of Industrial Relations is equal in rank with the Courts of First Instance. Second, the writs of preliminary injunction and prohibition may be issued only by a court to a tribunal or officer exercising judicial or ministerial functions lower in rank. Third, a Court of First Instance cannot issue these writs against the Court of Industrial Relations, and any action whose object is to nullify or restrain the enforcement of that court's writ of execution lies outside its jurisdiction. A Bar candidate should be able to state the rule as a single sentence: the extraordinary writs run downward, never sideways, so a court cannot enjoin a tribunal of equal rank.

Disposition

The Supreme Court granted the writ of certiorari and prohibition, without costs, declaring the respondent judge without jurisdiction over the prohibition case, and without prejudice to an ordinary action for damages against the private respondents other than the judge.

Remember This

Memorize the line: the writs of injunction and prohibition may issue only from a court to a tribunal or officer lower in rank, and the Court of Industrial Relations is equal in rank with the Courts of First Instance. Examiners use this case to test the hierarchy of courts and the reach of the extraordinary writs, often pairing it with questions on which court may restrain the acts of a co-equal tribunal.