SILVA PIPE WORKERS UNION-NATU, PETITIONER, VS. FILIPINO PIPE & FOUNDRY CORPORATION AND HON. PEDRO C. NAVARRO, RESPONDENTS.

Silva Pipe Workers Union versus Filipino Pipe and Foundry Corporation

The Case

This is a petition for certiorari and prohibition brought by the Silva Pipe Workers Union against the Filipino Pipe and Foundry Corporation and the presiding judge of the then Court of First Instance of Rizal, Branch Two. The Union asks the Supreme Court to nullify all proceedings in a civil action for damages and injunction that the Company had filed to restrain a strike. The Company had gone to the regular court, insisting that its suit was principally meant to prevent violent and unlawful acts. The Union answered that the matter was an unfair labor practice, and therefore belonged exclusively to the Court of Industrial Relations. The case matters because it fixes a jurisdictional boundary that bar candidates must know cold: when the acts complained of are intertwined with an unfair labor practice, the regular courts are without jurisdiction, even if the complaint alleges violence, intimidation, and coercion.

Procedural History

The Company filed a complaint for damages with preliminary injunction before the Court of First Instance of Rizal, Branch Two, praying that the Union be enjoined from continuing its strike, that the picket lines be lifted, that the strike be declared illegal, and that the Union be held liable for damages. The trial court issued an ex parte temporary restraining order with a bond of 3,000 pesos. The Union moved to dismiss on the ground that the case arose from an unfair labor practice exclusively cognizable by the Court of Industrial Relations. The trial court denied the motion and required the Union to file its answer. When the Union failed to file its answer within the statutory period, the trial court, upon the Company's motion, declared the Union in default. The Union sought reconsideration, which was denied. The Union then filed with the Supreme Court this petition for certiorari and prohibition with preliminary injunction, seeking to nullify all proceedings below. The Supreme Court resolved the petition directly, as an original action.

Facts

On 25 April 1970, the Company filed a civil case for damages with preliminary injunction against the Union. The Union had declared a strike, allegedly because the Company had refused to negotiate. The complaint prayed that the Union be enjoined from continuing the strike, that the picket lines be lifted immediately, that the strike be declared illegal, and that the Union be made liable for damages.

On 27 April 1970, the trial court issued an ex parte temporary restraining order with a bond of 3,000 pesos. The order directed the respondents and all persons acting in their behalf to stop preventing the ingress and egress of company officials and employees not involved in the strike, to allow free access to clients and customers, to remove all roadblocks, to refrain from threatening bodily harm, and to desist from all unlawful acts complained of.

Two days before the scheduled hearing on the writ of preliminary injunction, the Union moved to dismiss, arguing that the complaint arose from an unfair labor practice exclusively cognizable by the Court of Industrial Relations. The trial court denied the motion and required the Union to file its answer. Meanwhile, at the instance of the Company, a complaint for unfair labor practice was filed against the Union before the Court of Industrial Relations. On 24 December 1970, the trial court declared the Union in default for failure to file its answer within the statutory period. Reconsideration was denied, and the Union filed this petition.

Issues

• Whether or not the Court of First Instance of Rizal had jurisdiction to take cognizance of the civil case for damages and injunction.
• Whether or not the Court of Industrial Relations has exclusive jurisdiction over the labor dispute, including the power to issue a restraining order in connection therewith.

Applicable Provisions

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

The Court of Industrial Relations shall have jurisdiction over unfair labor practice cases, whether on the part of management or of a labor union.

This provision is the jurisdictional anchor: it vests in the Court of Industrial Relations the exclusive competence over unfair labor practice cases, which removes the present controversy from the regular courts.

Section 9, paragraph d, of Republic Act Number 875 provides:

These acts come within the purview of Section 9(d) of RA 875 which may be enjoined by CIR.

This provision is cited to show that even acts of violence, intimidation, and coercion fall within the power of the Court of Industrial Relations to enjoin, and not the regular courts.

Ruling

On the first issue, the Court ruled that the Court of First Instance was bereft of jurisdiction to take cognizance of the case before it. The unfair labor practice complaint filed by the Company before the Court of Industrial Relations unequivocally established that an unfair labor practice was involved, over which the Court of Industrial Relations had sole and exclusive jurisdiction. The Company's cause of action in the civil case arose out of, or was closely intertwined with, the unfair labor practice allegedly committed by the Union. It is sufficient that such a controversy exists to remove the case from the competence of the regular courts and to make it fall within the exclusive jurisdiction of the Court of Industrial Relations. The Court stressed that for the case to fall within that exclusive jurisdiction, an unfair labor practice need not be committed by management alone; labor may also be guilty thereof.

On the second issue, the Court rejected the Company's contention that the Court of First Instance had jurisdiction because the civil case was brought principally to prevent further commission of unlawful acts. The Court held that where the issue in the main case is interwoven with the unfair labor practice case pending before the Court of Industrial Relations, the trial court has no jurisdiction, even if the complaint alleges acts of violence, intimidation, and coercion. These acts come within the purview of Section 9, paragraph d, of Republic Act Number 875, which may be enjoined by the Court of Industrial Relations. The Court explained that the reason for such exclusive jurisdiction is that since picketing and strikes may be mere incidents or consequences of an unfair labor practice, it is but proper that a writ of injunction prayed for in connection with that labor dispute originate from the court having jurisdiction over the main case, inasmuch as it is that court that has cognizance of all relevant facts.

Doctrine

The Court of Industrial Relations has exclusive jurisdiction over labor disputes involving unfair labor practice, with the exclusive power to issue a temporary restraining order to enjoin any acts committed in connection with said labor dispute. This exclusive jurisdiction attaches whether the unfair labor practice is committed by management or by labor. Where the cause of action in a civil case is intertwined with an unfair labor practice, the regular courts are without jurisdiction, even if the complaint alleges violence, intimidation, and coercion, because those acts fall within the power of the Court of Industrial Relations to enjoin under Section 9, paragraph d, of Republic Act Number 875. The test is not the label of the complaint but the intertwining of the issues with the unfair labor practice case.

Disposition

The petition was granted; the temporary restraining order issued by the Court of First Instance of Rizal, Branch Two, was declared null and void; all proceedings before it in the civil case were set aside; and the court was permanently enjoined from taking any further action on the case except to dismiss the same, with no costs.

Remember This

The single line worth memorizing: where the acts complained of are intertwined with an unfair labor practice, the Court of Industrial Relations has exclusive jurisdiction, and the regular courts cannot act, even on allegations of violence, intimidation, and coercion. Examiners like to use this case to test the jurisdictional boundary between regular courts and labor tribunals, and to see whether you will be misled by a complaint that dresses up a labor dispute as a suit for damages and injunction.