Case Digest (G.R. No. L-16672)
Facts:
The case titled Associated Labor Union vs. The Honorable Judge Jose S. Rodriguez, et al. (G.R. No. L-16672, October 31, 1960) involves a petition for certiorari and prohibition where the petitioner, Associated Labor Union, is seeking to prohibit Judge Jose S. Rodriguez from proceeding with a case filed before him that leads to a preliminary injunction based on an alleged lack of jurisdiction. The events began on April 15, 1957, when Sweet Lines, a general co-partnership engaged in coast-wise shipping, contracted with Besanez & Canete Arrastre Service to manage the loading and unloading of cargo at the port of Cebu. On January 14, 1960, Besanez & Canete entered into a collective bargaining agreement with the United Free Workers Union, designating it as the exclusive representative of workers in the arrastre service. Subsequently, on January 27, 1960, the Associated Labor Union, representing dock workers formerly affiliated with the United Free Workers, asked for a collect
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Case Digest (G.R. No. L-16672)
Facts:
- Respondent Sweet Lines, a general co-partnership engaged in coast-wise shipping operating under the firm name Limpo & Sons, was involved in regular shipping business in the Philippines.
- On April 15, 1957, Sweet Lines entered into a contract with the Besanez & Canete Arrastre Service to handle the loading and unloading of cargoes at the port of Cebu.
Background and Contractual Relationships
- On January 14, 1960, the Besanez & Canete Arrastre Service executed a collective bargaining agreement with the United Free Workers Union, recognizing it as the exclusive bargaining representative for the workers in the arrastre service.
- On January 27, 1960, the Associated Labor Union—composed of dock workers formerly affiliated with the United Free Workers Union and employed in loading and unloading activities for Sweet Lines—wrote to both Sweet Lines and the arrastre service requesting that they enter into a collective bargaining contract with the union.
Labor Representations and Collective Bargaining Agreements
- Instead of acceding to the petitioning union's request, the Besanez & Canete Arrastre Service, through its capataz or foreman, allegedly coerced its workers into joining the United Free Workers Union; those who refused were subsequently denied work.
- In response, the petitioning union sent letters of protest to Sweet Lines and the arrastre company, supplying copies to the Conciliation Service of the Department of Labor.
Coercive Actions and Labor Conflict
- A conference was convened by the Conciliation Service in an effort to settle the differences, but no concrete agreement was reached, leading to heightened tensions between the parties.
- Approximately 135 members of the petitioning union struck on February 22, 1960, and simultaneously filed a charge of unfair labor practice with the Court of Industrial Relations against Sweet Lines and the Besanez & Canete Arrastre Service.
Escalation of Dispute and Strike
- On February 23, 1960, in reaction to the disruptive picketing by the union, Sweet Lines filed a complaint before the Court of First Instance of Cebu. The complaint sought to:
- Declare the picketing illegal and unlawful.
- Order the Associated Labor Union to pay damages and attorney’s fees amounting to P55,000.00.
- Issue, without notice, a writ of preliminary injunction to restrain the union from picketing Sweet Lines’ offices and vessels.
- After posting a bond of P2,000.00, the trial court granted the writ of preliminary injunction ex parte against the petitioning union.
- The following day, the union filed an urgent motion to lift the injunction; before the trial court could rule on this motion, the union initiated the petition for certiorari challenging the trial court’s action.
Filing of the Complaint and Issuance of Preliminary Injunction
Issue:
- Whether the respondent judge, by taking cognizance of the case filed before him, assumed jurisdiction which rightfully belonged to the Court of Industrial Relations, considering an unfair labor practice case was already pending before it.
- Whether the subject matter of the case, arising out of labor relations and disputes, falls exclusively within the jurisdiction of the industrial courts under the relevant labor statutes.
Jurisdiction
- Whether the ex parte issuance of the writ of preliminary injunction by the trial court was proper despite the absence of notice and hearing as mandated by either the Rules of Court or Republic Act 875.
- Whether the trial court’s reliance on the regular Rules of Court, instead of following the procedural requirements set forth in Republic Act 875 for labor disputes, led to a violation of due process.
Procedural Validity of the Preliminary Injunction
- Whether the peaceful picketing—a form of expression protected under the Constitution as part of free speech—can be legally enjoined, or if such an action constitutes an infringement upon constitutional rights.
- Whether the coercive actions regarding union affiliation and the subsequent suspension of work rights amounted to an unfair labor practice.
Constitutional and Legal Rights
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)