Facts:

The case involves Eddie del Castillo and fifteen co-plaintiffs, all members of the Associated Labor Union, who filed an appeal against the Central Azucarera de la Carlota and the National Sugar Workers' Union (PAFLU) after the Court of First Instance of Cebu dismissed their complaint for moral and exemplary damages amounting to P160,000, along with attorney's fees of P10,000. The events leading to this case began in 1962 when the plaintiffs, who were laborers at the Central Azucarera, were members of the National Sugar Workers' Union. In April or May of that year, the Associated Labor Union submitted proposals for a collective bargaining agreement to the Central, which were rejected. Following this, the Associated Labor Union filed petitions for a certification election with the Court of Industrial Relations (CIR) in Iloilo City. During this process, Simplicio Lopez, Jr., a signatory to the petitions, was suspended by the Central. The plaintiffs actively campaigne...

Facts:

Parties and Background

• Sixteen individual plaintiffs, including Eddie del Castillo, Cresencio Eslabon, Juanito Rodriguez, Simplicio Lopez, Jr., Rafael Dinglasa, Florencio Castel, Federico Ordanel, Balbino Talaver, Horacio Manalo, Supeniano Francisco, Pedro Talaver, Bienvenido Managuit, Oscar Tan, Antonio Mananquil, Rafael Poticar, and Cristino Alba, were laborers employed by Central Azucarera de la Carlota.
• Initially, these laborers were members of the National Sugar Workers’ Union (NSWU) until they resigned and later affiliated with the Associated Labor Union.
• The dispute arose following proposals submitted by the Associated Labor Union for a collective bargaining agreement which were rejected by Central.

Filing of Certification Election and Subsequent Dismissals

• After the rejection of the collective bargaining proposals, the Associated Labor Union filed petitions for a certification election with the Court of Industrial Relations (CIR) in Iloilo City (docketed as Nos. 57-MC-Iloilo and 58-MC-Iloilo).
• Simplicio Lopez, Jr., one of the signatories of these petitions, was suspended by Central, and thereafter, the sixteen plaintiffs were dismissed allegedly because they resigned from the NSWU and joined the Associated Labor Union.

Proceedings in the Court of Industrial Relations

• The plaintiffs, on account of their dismissal and the adverse effects on themselves and their families, filed a complaint for unfair labor practices before the CIR (Case No. 3385-ULP-Iloilo).
• The CIR found the defendants (Central and the NSWU) guilty of engaging in unfair labor practices, ordering Central to reinstate the plaintiffs with their corresponding rights and to pay wages during the period of suspension.
• Notably, the CIR did not grant moral and exemplary damages in its decision.

Subsequent Action in the Court of First Instance

• Relying on the alleged quasi-delict arising from the wrongful acts of the defendants, the plaintiffs instituted an action in the Court of First Instance of Cebu seeking recovery of moral and exemplary damages (P160,000) and attorney’s fees (P10,000).
• They argued that their claim was founded on articles 20, 21, and 2176 of the Civil Code, emphasizing that the CIR, being a court of limited jurisdiction, could not award such damages.

Motion to Dismiss and Lower Court Decision

• Defendants, including the National Sugar Workers’ Union, moved to dismiss the complaint alleging (a) lack of jurisdiction, (b) lack of cause of action, and (c) res judicata.
• The lower court sustained the motion to dismiss on the ground that the claim for damages was merely an incidental part of the earlier unfair labor practice case already decided by the CIR.

Core Controversy Raised on Appeal

• The legal question on appeal centered on whether the Court of First Instance had jurisdiction to entertain an action for damages based on alleged unfair labor practices, or whether such claims should have been consolidated and decided in the CIR proceeding.
• The controversy also involved whether allowing a separate civil action would amount to split jurisdiction in defiance of orderly judicial administration.

Issue:

Jurisdictional Authority

• Does the Court of First Instance have jurisdiction over an action for recovery of moral and exemplary damages arising from alleged unfair labor practices that are already subject matter to a proceeding in the CIR?
• Should the claim for damages be addressed independently in the regular court system or exclusively by the Industrial Court?

Res Judicata and Consolidation of Claims

• Is the separate action for damages barred by the principle of res judicata given that the underlying unfair labor practice was previously decided by the CIR?
• Can the plaintiffs pursue claims for quasi-delict (moral and exemplary damages) apart from the unfair labor dispute already adjudicated by the CIR?

Scope of Remedies and Court Competence

• Is it proper for a court of limited jurisdiction, like the CIR, to have exclusive competence over all issues—including damages—for industrial disputes?
• Does the absence of a grant for moral damages in the CIR decision justify a subsequent civil suit in a regular court?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)