G.R. No. L-26764 - Bachrach Transportation Co., Inc. vs. Rural Transit Shop Employees Association

The dispute originated when the Rural Transit Shop Employees Association (in conjunction with its sister union, Rural Transit Employees Association) went on strike on April 19, 1964, after the expiration of the 30‑day legally prescribed notice.
The unions claimed that their economic demands were not met and that the petitioner, Bachrach Transportation Company, Inc., committed unfair labor practices.
The Department of Labor’s conciliation efforts failed, prompting action by the President of the Philippines under Section 10 of the Industrial Peace Act.

On May 19, 1964, the President certified the labor dispute to the Court of Industrial Relations (CIR), docketing the case as Case 48‑IPA.
On May 20, 1964, the CIR issued an order directing all strikers to return to work immediately and mandating that the management reinstate them under the terms and conditions existing before the dispute.
Simultaneously, while the dispute remained pending, the petitioner was enjoined from dismissing any employee without the Court’s express authority.

Shortly after the CIR order, the petitioner began suspending and dismissing both traffic and shop employees, and transferring shop personnel between its main terminal in Caloocan City and various provincial stations (Nueva Ecija, Nueva Vizcaya, Isabela, and Cagayan).
Multiple ancillary petitions were triggered under Case 48‑IPA, including petitions for the discharge of drivers, conductors, and shop employees, petitions against non‑assignment, dismissals, and transfers, and specific petitions relating to individual employees.

Feliciano R. Cruz, a long‑serving employee since 1952 who had been primarily stationed at the Caloocan main terminal, was transferred to Bayombong, Nueva Vizcaya on July 14, 1966.
His transfer occurred immediately after he was present on July 13, 1966, at the hearing of Incidental Case No. 48‑IPA (42) where his son, Jose N. Cruz, testified.
On July 20, 1966, the respondent union filed an urgent petition for an injunction (Incidental Case 48‑IPA (46)) to restrain the petitioner from transferring employees without prior Court approval during the pendency of the main dispute.
Subsequent developments included the union’s motion to have the injunction apply to other employees after noting that the injunction became “moot and academic” in Feliciano R. Cruz’s case due to his dismissal.

On September 8, 1966, after due hearing in Incidental Case 48‑IPA (46), the CIR issued an order enjoining the petitioner from transferring any employees between the Main Terminal and provincial stations without its express authority, aiming to prevent further deterioration in the relationship between the parties.
The petitioner contested the injunction on the grounds that it interfered with the internal operations of the company and was beyond the CIR’s statutory authority.
On October 10, 1966, the CIR en banc denied the petitioner’s motion to reconsider the order.
Consequently, the petitioner elevated the case to the Supreme Court by certiorari, seeking to set aside the CIR’s orders.

The petitioner argued that the CIR lacked authority to issue the injunction, contending that the statutory power under Section 10 of the Industrial Peace Act did not extend to ordering a prohibition on transfers.
It further claimed that the injunction interfered with efficient operations and compromised public safety, given its status as a common carrier.
Additionally, the petitioner maintained there was no requisite showing of unfair labor practice, implying that the injunction was unjustified under the statutory regime, particularly in light of the requirements of Section 9(d) of Republic Act 875.

Does the CIR have the jurisdiction and authority under Section 10 of the Industrial Peace Act to issue an injunction restraining transfers of employees during a certified labor dispute?

Whether the injunctive order, which restrains employee transfers, unlawfully interferes with the petitioner’s internal operations, potentially affecting service efficiency and public safety.

Must there be a conclusively established case of unfair labor practice for the CIR to grant injunctive relief, or is such a finding unnecessary under Section 10 as distinguished from Section 9(d)?

Given that the injunction is ancillary to the main certified case, does it require an independent jurisdiction, or is its authority derived from that of the principal dispute?

How should the provisions of Section 10 be interpreted in light of Section 9(d), and what does this imply about the balance between protecting the status quo during labor disputes and the petitioner’s right to manage its operations?