Facts:

The case involves the Associated Labor Union, represented by Democrito T. Mendoza and Cecilio T. Seno, as petitioners against the Hon. Judge Modesto R. Ramolete of the Court of First Instance of Cebu, Katipunan Lumber Co., Inc., and Roque Abellar as respondents. The events leading to this case began when Katipunan Lumber Co., Inc. (hereafter referred to as "Katipunan") was engaged in the lumber business and employed a regular staff of office employees, drivers, and laborers affiliated with the Cebu Industrial Labor Organization, a recognized labor union. For occasional labor needs, Katipunan contracted independent labor contractors, including Cirilo Cabasa, who had a contract to supply laborers for non-routine tasks. On August 18, 1964, Cabasa requested to terminate his contract, leading to Roque Abellar entering into a new contract with Katipunan to provide labor for the same tasks previously handled by Cabasa.

On September 3, 1964, Katipunan and Abellar filed a...

Facts:

Parties and Nature of Business

• Respondent Katipunan Lumber Co., Inc. is engaged in the lumber business and employs regular staff for routine operations as well as independent contractors for occasional work.
• The case involves independent labor contractors, notably Cirilo Cabasa and Roque Abellar, who furnished labor for non-routine tasks.
• Petitioners include the Associated Labor Union, Democrito T. Mendoza, and Cecilio T. Seno, who challenged the conduct of Katipunan Lumber Co. and its agent.

Background and Contractual Relations

• Cirilo Cabasa had an existing contract with Katipunan to supply labor for occasional needs not covered by other independent contractors.
• On August 18, 1964, Cabasa requested termination of his contract.
• Roque Abellar, who had similar contracts with other lumber companies, subsequently entered into a written contract with Katipunan to furnish the needed labor.

Filing of Complaint and Injunction

• On September 3, 1964, Katipunan and Abellar filed a complaint before the Court of First Instance (CFI) of Cebu (Civil Case No. R-8564) seeking an injunction and damages.
• The complaint alleged that the respondents, including the petitioner labor union and its affiliates, engaged in coercive tactics—blocking truck passage, interfering with contractual obligations, and intimidating laborers and customers.
• The CFI issued a preliminary injunction on September 8, 1964, restraining the respondents from specific disruptive actions, subject to the posting of a bond of P50,000.00 by the plaintiffs.

Motion for Reconsideration and Lower Court Proceedings

• Defendants (petitioner labor union and its affiliates) filed a motion for reconsideration and to lift the preliminary injunction, contending:

- The lower court lacked jurisdiction to issue such an injunction. - Peaceful picketing was not subject to judicial restraint. - The prescribed requisites under Section 9(d) of Republic Act 875 were not followed. - An unfair labor practice case was pending involving the dispute.

Petition for Certiorari and Prohibition

• Before the resolution of the motion for reconsideration in the lower court, petitioners filed a petition for certiorari and prohibition with a preliminary injunction in the Supreme Court.
• Petitioners argued that the case was inherently a labor dispute, and the lower court had overstepped its jurisdiction by issuing an injunction that interfered with collective labor rights.
• Respondents countered that the petition was premature as the lower court had already provided remedial measures, including the opportunity to present evidence concerning the existence of a labor dispute.
• Evidence was pending regarding the nature of the dispute, and multiple procedural steps had already been undertaken in the lower court.

Relevant Developments and Judicial Proceedings

• The lower court had deferred resolving the motion for reconsideration pending further evidence to establish whether the case involved a labor dispute or a simple contractual dispute for damages.
• The Supreme Court observed that the petition was filed prematurely and that alternative remedies were available in the lower court, notably once the disputed factual issues regarding a labor dispute were thoroughly examined.
• The issues raised concerning jurisdiction and the proper exercise of injunctive powers were tied to the initial allegations for damages and interference with contractual obligations versus the later contention of a labor dispute.

Issue:

Jurisdictional Inquiry

• Whether the Court of First Instance had proper jurisdiction over the case based on the allegations in the complaint, which primarily sought recovery of damages and interference with contractual obligations.
• Whether the contention that the dispute was a labor dispute, thereby necessitating a different procedural approach, would automatically divest the lower court of jurisdiction.

Validity of the Preliminary Injunction

• Whether the issuance of the preliminary injunction ex parte, based on the evidence and circumstances at the time, was within the powers of the lower court.
• Whether the actions enjoined were beyond the ambit of protections granted under Section 9(a) or Section 9(d) of Republic Act 875.

Appropriateness of the Petition for Certiorari and Prohibition

• Whether the filing of the petition for certiorari and prohibition was premature given that remedial actions were available in the lower court.
• Whether the petitioners failed to exhaust all available remedies before escalating the issue to the Supreme Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)