Title
Abo vs. Philame Employees and Workers Union
Case
G.R. No. L-19912
Decision Date
Jan 30, 1965
Employees sued union members for blocking workplace access, seeking damages. Court ruled jurisdiction valid, remanded case as acts didn't constitute unfair labor practice under Industrial Peace Act.
A

Case Digest (G.R. No. L-19912)

Facts:

Aurelta Abo, et al. v. Philame (Kg) Employees & Workers Union, Philippine Transport & General Workers Organization, et al., G.R. No. L-19912, January 30, 1965, the Supreme Court En Banc, Regala, J., writing for the Court.

The plaintiffs-appellants are employees of Philippine American Embroideries, Inc. On May 11, 1961 they filed a complaint in the Court of First Instance of Rizal (Civil Case No. 6637) alleging that from March 24, 1961 up to May 6, 1961 the individual defendants, acting as officers and/or members of the defendant labor unions and in their individual capacities, "by concerted action and with their full knowledge, approval and consent, prevented the plaintiffs by the use of force, violence and intimidation from entering the premises of the KG Department of the Philippine Embroideries, Inc." The complaint sought P,410.75 for wages allegedly not earned, P5,000 for moral damages, P5,000 for exemplary damages, and P1,000 for attorney’s fees.

Instead of answering, the defendants filed a motion to dismiss alleging lack of jurisdiction of the trial court because (a) the acts complained of constituted an unfair labor practice within the exclusive jurisdiction of the Court of Industrial Relations (CIR) under the Industrial Peace Act (Republic Act No. 875), (b) the labor dispute had already been amicably settled, and (c) the subject matter was the subject of an unfair labor practice case then pending in the CIR in which plaintiffs should have intervened. In an order dated November 2, 1961 the Court of First Instance dismissed the complaint for lack of jurisdiction, relying on Section 4(b)(1) and Section 24 of the Industrial Peace Act.

The plaintiffs appealed from the dismissal to the Supreme Court. The Court wa...(Subscriber-Only)

Issues:

  • Did the Court of First Instance lack jurisdiction because the acts alleged in the complaint fell within the exclusive jurisdiction of the Court of Industrial Relations as unfair labor practices under the Industrial Peace Act?
  • Is jurisdiction to be determined solely from the allegations of the complaint, or may the court look to evidence adduced by the parties in resolving a motion to dismiss for lack of jurisdiction?
  • Could Section 24 of the Industrial Peace Act, which protects certain acts done in furtherance of an industrial dispute,...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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