Title
Associated Labor Union vs. Rodriguez
Case
G.R. No. L-16672
Decision Date
Oct 31, 1960
ALU contested jurisdiction and injunction in a labor dispute with Sweet Lines and Besanez & Canete Arrastre Service, claiming unfair labor practices and improper court intervention.
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Case Digest (G.R. No. L-16672)

Facts:

    Background and Contractual Relationships

    • 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.

    Labor Representations and Collective Bargaining Agreements

    • 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.

    Coercive Actions and Labor Conflict

    • 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.

    Escalation of Dispute and Strike

    • 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.

    Filing of the Complaint and Issuance of Preliminary Injunction

    • 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.

Issue:

    Jurisdiction

    • 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.

    Procedural Validity of the Preliminary Injunction

    • 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.

    Constitutional and Legal Rights

    • 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.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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