Title
Associated Labor Union vs. Borromeo
Case
G.R. No. L-26461
Decision Date
Nov 27, 1968
ALU's picketing at SUGECO and related sites was deemed lawful; CFI lacked jurisdiction, and injunctions violated labor law requirements.
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Case Digest (G.R. No. L-26461)

Facts:

Background of the Parties

  • Associated Labor Union (ALU): A duly registered labor organization whose members include employees of Superior Gas and Equipment Company of Cebu, Inc. (SUGECO).
  • SUGECO: A domestic corporation with offices and a plant in Cebu, engaged in the production of gas and related equipment.

Collective Bargaining Agreement (CBA)

  • ALU and SUGECO entered into a collective bargaining contract effective until January 1, 1966.
  • Negotiations for the renewal of the CBA began before its expiration. However, these negotiations stalled when 12 SUGECO employees resigned from ALU in late February 1966.
  • ALU alleged that SUGECO’s supervisors coerced the resignations, an act amounting to unfair labor practices.

Strike and Injunction

  • On March 4, 1966, ALU declared a strike and established picket lines at the SUGECO plant in Mandaue.
  • The next day, SUGECO filed Civil Case No. R-9221 in the Court of First Instance (CFI) of Cebu, seeking to restrain ALU from picketing. The court issued an ex-parte writ of preliminary injunction.
  • ALU challenged this injunction in the Supreme Court (Case No. L-25999), which ruled in favor of ALU on May 16, 1966, lifting the injunction and declaring it permanent on February 9, 1967.

Expansion of Picketing

  • After the Supreme Court’s decision, ALU resumed picketing at SUGECO’s plant and extended it to:
    • The residence of SUGECO’s general manager, Mrs. Lua, and her husband, Antonio Lua.
    • The store of Cebu Home and Industrial Supply, owned and managed by Antonio Lua, which sold SUGECO products.

Case No. R-9414

  • On June 21, 1966, Cebu Home and Antonio Lua filed Civil Case No. R-9414 in the CFI of Cebu, seeking to restrain ALU from picketing their store and residence and to recover damages.
  • Judge Borromeo issued writs of preliminary injunction on June 30, 1966, and July 22, 1966, restraining ALU’s picketing activities.

Issue:

  1. Whether the CFI of Cebu had jurisdiction over Case No. R-9414, which grew out of a labor dispute.
  2. Whether the writs of preliminary injunction issued by Judge Borromeo were valid, particularly in light of the requirements of Section 9 of Republic Act No. 875 (the Industrial Peace Act).
  3. Whether ALU’s picketing of Cebu Home and the Lua residence was lawful under the circumstances.

Ruling:

The Supreme Court ruled in favor of ALU, declaring the writs of preliminary injunction null and void. The Court held that:

  1. The CFI of Cebu lacked jurisdiction over the case, as it involved a labor dispute falling under the exclusive jurisdiction of the Court of Industrial Relations (CIR).
  2. The writs of preliminary injunction failed to comply with the procedural requirements of Section 9 of Republic Act No. 875, particularly the necessity of findings of fact to justify their issuance.
  3. ALU’s picketing of Cebu Home and the Lua residence was lawful, as Cebu Home was engaged in the same trade as SUGECO and had an indirect interest in the labor dispute.

Ratio:

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