Facts:

The case involves Teresita Alo and the Federation of Free Farmers (FFW) as petitioners against Hon. Valerio V. Rovira, the Presiding Judge of the Court of First Instance (CFI) of Iloilo City, Branch IV, along with private respondents Genoveva So Chan Too, Sy Kian Tiok, and the Provincial Sheriff of Iloilo. The events leading to this petition began in August 1971 when Teresita Alo, employed as a cashier at the Iloilo Shanghai Bazar owned by the private respondents, organized a local chapter of the FFW, naming it the Iloilo Shanghai Bazar Workers Union FFW. On August 26, 1971, the FFW sent a letter to the private respondents requesting recognition as the bargaining agent for the employees of the Bazar. Instead of responding, the private respondents filed a petition for a certification election with the Court of Industrial Relations (CIR), which was docketed as Case No. 129-MC-Iloilo. During her leave from August 1 to 15, 1971, to attend a labor seminar, Alo was demoted upon her...

Facts:

Background of the Case

• Teresita Alo and the Federation of Free Workers (FFW) filed a Petition for Certiorari seeking annulment of an order issued by the then Court of First Instance (CFI) of Iloilo City, Branch IV.
• The petition challenged an Order dated September 11, 1971, granting a writ of preliminary injunction, and the corresponding writ dated September 13, 1971, which enjoined petitioners and their sympathizers from picketing in front of the Iloilo Shanghai Bazar.

Chronology and Relevant Events

• During August 1971, while employed as a cashier at the Iloilo Shanghai Bazar, Teresita Alo organized a local chapter of the FFW, naming it the Iloilo Shanghai Bazar Workers Union FFW.
• On August 26, 1971, the FFW sent a letter to private respondents requesting recognition of their organization as the bargaining agent for the store’s employees.
• Instead of responding to the letter, private respondents filed a petition for a certification election with the Court of Industrial Relations (CIR) under Case No. 129-MC-Iloilo.
• Earlier in August 1971, Teresita Alo attended a labor seminar (from August 1 to 15, 1971), and upon her return on August 16, 1971, she was demoted from her position as cashier to an ordinary sales girl.
• On August 27, 1971, amid the ongoing labor dispute, Teresita Alo was dismissed due to her union activities.
• On September 2, 1971, the FFW filed a notice of strike with the Department of Labor, contesting the dismissal and management's refusal to bargain.
• That same day, petitioners and sympathizers staged a picket at the premises of the Iloilo Shanghai Bazar.
• Subsequently, on September 10, 1971, a charge for Unfair Labor Practice, along with violations of the Eight-Hour Labor Law and Minimum Wage Law, was filed with the CIR (docketed as Charge No. 206-Iloilo).
• Private respondents, comprising Genoveva So Chan Too and Sy Kian Tiok, also initiated a civil action for damages (Civil Case No. 8769) before the CFI, alleging loss of income due to the picketing.
• On September 11, 1971, after hearing the matter, the presiding judge of the CFI issued the order granting the writ of preliminary injunction, which is now under petition challenge.

Interrelation of the Disputes

• The acts complained of in the unfair labor practice charge and those giving rise to the civil action for damages are interwoven; both relate to the same labor dispute arising from Teresita Alo’s union activities.
• The controversy centers on whether the CFI had jurisdiction over a matter that involves labor dispute issues.

Pertinent Legal Developments

• The case references the Veterans Security Free Workers Union vs. Hon. Gaudencio Cloribel case, which emphasized that disputes arising from unfair labor practices fall exclusively within the jurisdiction of the CIR.
• Later, Presidential Decree No. 442 (the Labor Code of the Philippines), effective May 1, 1974, abolished the CIR and reallocated jurisdiction for unfair labor practice cases to the Labor Arbiter and National Labor Relations Commission (NLRC).
• The evolution of labor law jurisdiction further underscores the controversy over whether a civil court (CFI/Regional Trial Court) may decide labor disputes.

Issue:

Jurisdictional Inquiry

• Does the Court of First Instance have jurisdiction over cases involving labor disputes, particularly those arising from alleged unfair labor practices?
• Can a civil action for damages, which intertwines with a labor dispute, override the exclusive labor jurisdiction originally vested in the CIR or later the NLRC under PD No. 442?

Procedural and Substantive Aspects

• Was it proper for the lower court to entertain and issue an injunction relief in a case where the underlying controversy is essentially a labor dispute?
• Does the precedent indicating the exclusive jurisdiction of labor bodies apply even if the civil case was filed prior to the filing of the unfair labor practice charge?

Impact of Legislative Changes

• How does the enactment of PD No. 442 affect the question of jurisdiction in this case?
• Does the shift in statutory jurisdiction from the CIR to the NLRC negate or prevent the lower court’s authority over such disputes?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)