Facts:

In January 1957, the Balaquezon Transportation Labor Union (Chapter VII-B) filed complaints with the Court of Industrial Relations against the Laguna Tayabas Bus Company, alleging unfair labor practices. Specifically, they charged the company with dismissing employees due to their union activities and sponsoring a company union. These actions led to multiple cases, including the unjustified dismissal of employee Pedro Ordono on November 22, 1956. On June 25, 1957, the union initiated a strike to protest these dismissals and the company's support for a competing union. On July 6, 1957, a temporary agreement was reached between the unions and the company to hold an election to determine the collective bargaining representative from July 9 to 11, which was later rescheduled to July 16-18. However, the counting of votes was hindered when Dr. Marcelino T. Enriquez, the union president, refused to provide the keys to the ballot boxes, citing alleged interference from the company.

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Facts:

Initiation of Labor Dispute

• In January 1957, the Balaquezon Transportation Labor Union (Chapter VII-B) filed several complaints for unfair labor practices against the Laguna Tayabas Bus Company.
• The union alleged that the Company interfered with employees’ right to self-organization by dismissing them for participating in union activities and by sponsoring a company union.

Filing of Charges and Consolidation of Cases

• On 23 February 1957, acting prosecutor Pascual Y. Reyes charged the Company with unjustifiably dismissing Pedro Ordono, a driver, on account of his union activities.
• Subsequent complaints were consolidated on 25 June 1957, combining several cases under one umbrella dispute.

Strike and Temporary Agreements

• On 25 June 1957, the workers, under the union’s directive, went on strike to prevent further layoffs and to protest union interference, specifically targeting the Company’s support for its company union, the Laguna Tayabas Bus Company Employees’ Association.
• On 6 July 1957, to resolve widespread transportation disruptions in Quezon, Rizal, and Laguna provinces, the union, the Company, and the Employees’ Association entered into a temporary agreement that recalled the picket lines.
• The parties agreed, upon the Labor Secretary’s suggestion, to hold an election under the Department of Labor’s supervision to determine which union would serve as the exclusive collective bargaining representative.

Election Arrangements and Subsequent Disruptions

• A preliminary agreement scheduled the election for 9, 10, and 11 July 1957 and defined the eligible voters as all employees listed on the Company’s payroll as of 25 June 1957.
• On 9 July 1957, the parties entered into a supplementary agreement to postpone the election to 16, 17, and, if necessary, 18 July 1957 and reiterated voter eligibility terms.
• On 10 July 1957, during the proper proceedings, the union charged the Company with interfering, restraining, and coercing its employees in exercise of their self-organizational rights.
• The election proceeded on 16–18 July 1957; however, the counting and canvassing of ballots were halted because Dr. Marcelino T. Enriquez, the union’s president, refused to surrender the keys to the ballot boxes, citing interference by the Company which allowed employees from Eastern Tayabas Bus Lines to vote.

Intervention of the Laguna Tayabas Bus Company Employees’ Association and Injunctive Relief

• On 22 July 1957, the Employees’ Association filed a case in the Court of First Instance of Laguna seeking a writ of prohibitory and mandatory injunction to (a) stop the union from interfering with Company operations, (b) command the union to produce the ballot boxes’ keys, and (c) direct the Board of Election and Canvassers to count and declare the election result.
• The court, after the Employees’ Association posted a bond of P2,000, issued an ex parte preliminary writ of prohibitory injunction against the union.
• In a parallel order, the court directed the ballot-counting body to proceed with the election count under threat of contempt if they failed to comply.

Subsequent Petition by the Union

• On 24 July 1957, the Balaquezon Transportation Labor Union filed a petition for a certification election in the Court of Industrial Relations, questioning the election’s validity despite prior agreements.
• The union later brought a petition for a writ of certiorari and prohibition, seeking annulment of the preliminary injunction issued ex parte by the Laguna Court.
• The union argued that the injunction was issued without notice and hearing, violating Section 9(d) of Republic Act No. 875 (Industrial Peace Act), which mandates an open hearing in labor disputes.

Respondents’ Position

• The Laguna Tayabas Bus Company Employees’ Association and the Laguna Tayabas Bus Company contended that the dispute did not qualify as a “labor dispute” but rather involved enforcement of the interim agreements.
• They maintained that, under the exceptional provisions of Rule 60, Sections 4 and 5, the court had jurisdiction to issue an ex parte writ in this context.

Determination of the Nature of the Dispute

• The Court recognized that despite the existence of temporary agreements, the underlying conflict remained a labor dispute.
• The dispute involved controversies related to employees’ rights, union representation, and allegations of interference—issues central to the definition of a labor dispute.

Issue:

Jurisdictional Question

• Whether the Court of First Instance of Laguna had proper jurisdiction to issue an ex parte preliminary writ of prohibitory injunction in a case involving a labor dispute subject to the provisions of the Industrial Peace Act (Republic Act No. 875).
• Whether the enforcement of the temporary agreements (regarding the election and cessation of the strike) falls outside or within the scope of a labor dispute that mandates an evidentiary hearing.

Procedural Compliance

• Whether the issuance of a permanent injunction without notice and hearing contravenes Section 9(d) of Republic Act No. 875, which requires that no permanent injunction be issued in labor disputes except after an ex parte hearing where witnesses may be heard and cross-examined.
• Whether the union’s failure to surrender the keys to the ballot boxes and the resulting stoppage of the election process constitutes a sufficient ground to justify the injunction.

Characterization of the Dispute

• Whether the controversy, given its focus on union representation and self-organization, qualifies as a labor dispute under the law, irrespective of the parties’ framing regarding a contractual or enforcement issue under the interim agreements.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)