Title
Associated Labor Union vs. Gomez
Case
G.R. No. L-25999
Decision Date
Feb 9, 1967
Union-Sugeco labor dispute over unfair practices, strike, and jurisdictional conflict; Supreme Court ruled CIR has exclusive jurisdiction, nullifying lower court's injunction.
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Case Digest (G.R. No. L-25999)

Facts:

Collective Bargaining Agreement and Negotiations

  • On January 1, 1965, the Associated Labor Union (Union) and Superior Gas and Equipment Co. of Cebu, Inc. (Sugeco) entered into a collective bargaining contract set to expire on January 1, 1966.
  • Prior to the contract's expiration, both parties began negotiations for its renewal.

Resignation of Employees and Breakdown of Negotiations

  • In February 1966, 12 of Sugeco's employees resigned from the Union while negotiations were ongoing.
  • The Union requested Sugeco to prevent the 12 resigned employees from reporting to work unless they produced a clearance from the Union.
  • Sugeco rejected the request, citing irreparable injury, the expiration of the bargaining contract, and the inability to demand such clearance.

Allegations of Unfair Labor Practices

  • The Union accused Sugeco of bargaining in bad faith and alleged that Sugeco's supervisors campaigned for the resignation of Union members.
  • The Union threatened to strike unless Sugeco stopped the alleged unfair labor practices and signed a new collective bargaining agreement.

Strike and Legal Actions

  • On March 3, 1966, Sugeco's counsel stated that the Union no longer represented the majority of employees due to the resignations.
  • On March 4, 1966, the Union declared a strike and picketed Sugeco's Basak plant.
  • On March 5, 1966, Sugeco filed a case in the Court of First Instance of Cebu (Case No. R-9221) seeking to restrain the Union's picketing activities.
  • On the same day, the Union filed an unfair labor practice charge against Sugeco in the Court of Industrial Relations (CIR).

Injunction and Jurisdictional Dispute

  • The Court of First Instance issued a preliminary injunction against the Union's picketing.
  • The Union challenged the jurisdiction of the Court of First Instance, arguing that the CIR had exclusive jurisdiction over unfair labor practices.

Issue:

  1. Whether the Court of First Instance of Cebu had jurisdiction over the subject matter of the case, specifically the alleged unfair labor practices.
  2. Whether the writ of preliminary injunction issued by the Court of First Instance was valid.

Ruling:

  • The Supreme Court ruled that the Court of First Instance of Cebu lacked jurisdiction over the subject matter of the case.
  • The Court held that the alleged unfair labor practices fell within the exclusive jurisdiction of the Court of Industrial Relations (CIR).
  • The writ of preliminary injunction issued by the Court of First Instance was declared null and void.
  • The Court granted the Union's petition for certiorari and prohibition, making the cease-and-desist order permanent and directing the dismissal of Case No. R-9221.

Ratio:

  • The Industrial Peace Act vests exclusive jurisdiction over unfair labor practices in the CIR.
  • The allegations of coercion and unfair labor practices by both the Union and Sugeco squarely fall under the jurisdiction of the CIR.
  • The Court emphasized that labor disputes involving unfair labor practices should not be subject to split jurisdiction, as it undermines the orderly administration of justice.
  • The Union's strike and the subsequent legal actions were directly related to the alleged unfair labor practices, reinforcing the CIR's exclusive jurisdiction.
  • The Court reaffirmed the principle that labor cases involving unfair labor practices are within the exclusive jurisdiction of the CIR, a rule that has become a well-established doctrine in Philippine jurisprudence.


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