GOODRICH EMPLOYEES ASSOCIATION, PETITIONER, VS. THE HONORABLE DELFIN B. FLORES, JUDGE OF THE COURT OF FIRST INSTANCE OF RIZAL, PASIG BRANCH XI AND B. F. GOODRICH PHILIPPINES, IN…

Goodrich Employees Association versus Flores

The Case

This is a special civil action for certiorari and prohibition brought by the Goodrich Employees Association against Judge Delfin B. Flores of the Court of First Instance of Rizal, Pasig Branch Eleven, and against the employer B. F. Goodrich Philippines, Incorporated. The union asks the Supreme Court to nullify the orders of the trial judge, who entertained and decided a civil suit for damages filed by the employer arising from a strike that the employer itself had already charged as an unfair labor practice before the Court of Industrial Relations. The case matters because it fixes, in the strongest terms, the boundary between the regular courts and the labor tribunal: where the matter is an unfair labor practice, jurisdiction belongs exclusively to the labor court, and a claim for damages flowing from that same act cannot be split off and litigated elsewhere.

Procedural History

The employer, B. F. Goodrich Philippines, Incorporated, filed a complaint for damages in the Court of First Instance of Rizal, Pasig Branch Eleven, presided over by Judge Delfin B. Flores. The union moved to dismiss on the ground of lack of jurisdiction, but the trial judge denied the motion. The case proceeded to judgment, and the trial court rendered a decision in favor of the employer, later amending its dispositive portion, and still later issuing a writ of execution. From these orders the union came to the Supreme Court by a petition for certiorari and prohibition. The Court noted that a prior petition of a similar nature between the same parties had been dismissed by minute resolution without prejudice, and it held that such dismissal was no bar, there being no res judicata. Finding the question of sufficient moment, the Court required the respondents to answer the petition.

Facts

The employer filed with the Court of Industrial Relations an unfair labor practice charge against the union based on a strike. While that charge was pending, and based on the very same strike, the employer filed a civil suit for damages against the union and its officers before Judge Flores in the Court of First Instance of Rizal. The suit was filed in October 1965.

On June 5, 1967, the union moved to dismiss the civil suit precisely on the ground of lack of jurisdiction. By then the Supreme Court had already promulgated its ruling in Associated Labor Union versus Gomez, decided in February 1967, holding that a court of first instance has no jurisdiction over a matter that properly belongs to the Court of Industrial Relations. Despite that controlling doctrine, Judge Flores denied the motion to dismiss.

The trial court then rendered judgment against the union and its named officers, and later amended the dispositive portion to direct them to pay the employer 686,700 pesos plus interest at one percent per month from January 1966 until fully paid, 25,000 pesos as moral damages, 25,000 pesos as exemplary damages, 50,000 pesos as attorney's fees, and the costs of suit. In January 1969 the court ordered a writ of execution for the full satisfaction of these claims, an order the Supreme Court described as one that could deal a death-blow to the union.

Issues

• Whether or not a court of first instance has jurisdiction to entertain a suit for damages filed by an employer arising from a strike that is the subject of a pending unfair labor practice charge before the Court of Industrial Relations.
• Whether or not the trial judge, having assumed jurisdiction before the controlling doctrine was promulgated, was excused from applying that doctrine when the motion to dismiss was filed after its promulgation.
• Whether or not the prior minute resolution dismissing a similar petition between the same parties barred the present petition by res judicata.

Applicable Provisions

The decision rests on the exclusive jurisdiction of the Court of Industrial Relations over unfair labor practice cases under the Industrial Peace Act. The Court, through Justice Teehankee in a cited ruling, referred to the explicit provision of Section 5(a) of that Act, which provides:

It has long been accepted as dogma that cases involving unfair labor practice fall within the exclusive jurisdiction of the Court of Industrial Relations, by virtue of the explicit provision of Section 5(a) of the Industrial Peace Act.

This provision is the statutory anchor of the rule that withdraws unfair labor practice controversies from the regular courts and lodges them in the labor tribunal.

The Court also invoked the constitutional protection to labor under the 1935 Constitution, Article Fourteen, Section Six, which provides:

The State shall afford protection to labor, especially to working women and minors, and shall regulate the relations between landowner and tenant, and between labor and capital in industry and in agriculture. The State may provide for compulsory arbitration.

This provision bears on the case because the Court measured the trial court's assumption of jurisdiction against the constitutional mandate to protect labor.

Finally, the Court cited Article Two, Section Five of the 1935 Constitution on social justice, which provides:

The promotion of social justice to insure the well-being and economic security of all the people should be the concern of the State.

This provision frames the Court's conclusion that a regular court, ill-equipped to apply labor laws, should not sit in judgment over a labor controversy.

Ruling

On the first issue, the Court held that the trial court was devoid of jurisdiction. The matter belonged to the Court of Industrial Relations. The Court quoted with approval the doctrine in Associated Labor Union versus Gomez:

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. To hold otherwise is to sanction split jurisdiction, which is obnoxious to the orderly administration of justice.

It likewise adopted the reasoning in Progressive Labor Association versus Atlas Consolidated Mining and Development Corporation, that the mere allegation of damages does not divest the labor court of jurisdiction, because the right to damages still depends on the evidence in the unfair labor case. The Court stressed that cases involving unfair labor practice are within the exclusive jurisdiction of the labor court, a rule it said has ripened into dogma, and that where the subject matter is within the competence of that court, it has jurisdiction over all incidental matters connected with the main issue.

On the second issue, the Court acknowledged that when the judge assumed jurisdiction in 1965 he could not have known any better, since the Gomez ruling came only in February 1967. But no such excuse could be relied upon when the motion to dismiss was presented in June 1967, after that ruling had appeared. The judge ought to have granted the motion; instead he denied it, acting contrary to controlling decisions.

On the third issue, the Court held that there was no res judicata. The prior minute resolution dismissing a similar petition without prejudice was no bar, and the Court's own resolution requiring an answer showed that the defense had been considered and found lacking in merit.

The Court added that the challenged orders were void for having been issued without jurisdiction, and it described a void judgment as a lawless thing that may be treated as an outlaw and slain at sight or ignored wherever it exhibits its head.

Doctrine

Cases involving unfair labor practice fall within the exclusive jurisdiction of the Court of Industrial Relations, and a claim for damages arising from the same act cannot be brought separately in a regular court, because the right to damages depends on the evidence in the unfair labor practice case. To allow the split is to sanction split jurisdiction, which is obnoxious to the orderly administration of justice. Where the subject matter is within the competence of the labor court, that court has jurisdiction over all incidental matters connected with the main issue. Orders issued by a court without jurisdiction are void and may be set aside on certiorari and prohibited from further enforcement.

Disposition

The Supreme Court granted the writ of prohibition, perpetually restraining the successor of Judge Flores from taking any further action in the civil case except to dismiss it, and granted the writ of certiorari, setting aside and nullifying the trial court's decision and its order of execution for having been issued without jurisdiction, with no costs.

Remember This

Memorize this line: an unfair labor practice case belongs exclusively to the labor tribunal, and a claim for damages arising from the same act cannot be split off into a regular court. Examiners use this case to test jurisdiction over unfair labor practice and the prohibition against split jurisdiction.