Title
Associated Labor Union vs. Ramolete
Case
G.R. No. L-23537
Decision Date
Mar 31, 1965
Labor union challenges CFI jurisdiction and ex parte injunction in dispute over alleged unlawful interference with contractual obligations, deemed premature by SC.
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Case Digest (G.R. No. L-23537)

Facts:

  1. Parties Involved:

    • Petitioners: Associated Labor Union (ALU), Democrito T. Mendoza, and Cecilio T. Seno.
    • Respondents: Hon. Judge Modesto R. Ramolete of the Court of First Instance (CFI) of Cebu, Katipunan Lumber Co., Inc. (Katipunan), and Roque Abellar.
  2. Background of Katipunan Lumber Co., Inc.:

    • Katipunan is engaged in the lumber business and maintains a permanent staff of office employees, drivers, and laborers affiliated with the Cebu Industrial Labor Organization.
    • For occasional work, Katipunan engages independent labor contractors, including Cirilo Cabasa, who supplied laborers for non-routine tasks.
  3. Contractual Dispute:

    • On August 18, 1964, Cirilo Cabasa terminated his contract with Katipunan.
    • Roque Abellar, another independent contractor, entered into a written contract with Katipunan to supply laborers for tasks previously handled by Cabasa.
  4. Legal Action:

    • On September 3, 1964, Katipunan and Abellar filed a complaint (Civil Case No. R-8564) in the CFI of Cebu against ALU, Mendoza, and Seno, seeking an injunction and damages.
    • The complaint alleged that ALU and its members were engaging in coercive and harassing tactics, interfering with Katipunan’s contractual obligations.
    • Katipunan denied any employer-employee relationship with Abellar’s laborers, asserting that Abellar had full control and supervision over them.
  5. Injunction Issued:

    • On September 8, 1964, Judge Ramolete issued a preliminary injunction, restraining ALU and its members from:
      • Blocking Abellar’s trucks.
      • Disturbing Abellar’s laborers.
      • Interfering with Katipunan’s business operations.
    • The injunction was issued ex parte upon the posting of a P50,000 bond.
  6. Petitioners’ Motion for Reconsideration:

    • ALU filed a motion to lift the injunction, arguing:
      • The CFI lacked jurisdiction as the case involved a labor dispute.
      • Peaceful picketing cannot be enjoined.
      • The requirements of Section 9(d) of Republic Act No. 875 (Industrial Peace Act) were not followed.
      • An unfair labor practice case was already pending before the Court of Industrial Relations (CIR).
  7. Respondents’ Opposition:

    • Katipunan and Abellar opposed the motion, asserting that the CFI had jurisdiction based on the complaint’s allegations.
    • They argued that the injunction was not against peaceful picketing but against unlawful interference with contractual obligations.
  8. Petition to the Supreme Court:

    • Without waiting for the CFI’s resolution, ALU filed a petition for certiorari and prohibition with the Supreme Court, challenging the CFI’s jurisdiction and the issuance of the injunction.

Issue:

  1. Whether the CFI had jurisdiction over the case, given the allegations of a labor dispute.
  2. Whether the issuance of the preliminary injunction by the CFI was proper, particularly in light of the provisions of Republic Act No. 875.
  3. Whether the petition for certiorari and prohibition was prematurely filed, as the CFI had not yet resolved the motion for reconsideration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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