Case Digest (G.R. No. L-22584)
Facts:
The case involves two petitions: G.R. No. L-22584 filed by the DBP Employees Union-NATU against Hon. Jesus Y. Perez, the Sheriff of the City of Manila, and the Development Bank of the Philippines (DBP), and G.R. No. L-23083, where the DBP is the plaintiff against the same union and its president, Delia P. Medina. The events leading to the case began with a labor dispute involving the DBP and its employees' union, which announced a strike on March 4, 1964. The DBP sought a preliminary injunction from the Court of First Instance of Manila to prevent the strike, claiming that the union's actions violated a collective bargaining agreement that renounced strikes. The trial court issued a writ of preliminary injunction, which the union contested, arguing that the court lacked jurisdiction over the labor dispute, which should fall under the exclusive jurisdiction of the Court of Industrial Relations. The lower court ultimately ruled in favor of the DBP, ordering the union to...
Case Digest (G.R. No. L-22584)
Facts:
Background of the Case:
- The case involves two consolidated petitions: G.R. No. L-22584 (a petition for certiorari and prohibition) and G.R. No. L-23083 (an appeal from a final judgment).
- The petitioner in G.R. No. L-22584 is the DBP Employees Union-NATU, while the respondents are Hon. Jesus Y. Perez, the Sheriff of the City of Manila, and the Development Bank of the Philippines (DBP).
- In G.R. No. L-23083, the DBP is the plaintiff-appellee, and the defendants-appellants are the DBP Employees Union (DBPEU-NATU), Delia P. Medina (as president of DBPEU), and the National Trade Union (NATU).
Nature of the Dispute:
- The dispute arose from a labor strike declared by the DBPEU-NATU against the DBP.
- The DBP filed Civil Case No. 54374 in the Court of First Instance of Manila, seeking to enjoin the strike and claiming damages for losses incurred during the strike.
Key Agreements:
- The parties had entered into a Collective Bargaining Agreement (CBA) on December 29, 1961, wherein the union renounced strikes and other non-peaceful measures.
- On January 15, 1963, the parties agreed to submit the question of whether the DBP performs governmental or proprietary functions to the Secretary of Justice, who ruled that the DBP exercises governmental functions.
Strike and Injunction:
- The union announced a strike on March 4, 1964, which ended on March 20, 1964, with a return-to-work agreement.
- The trial court issued a writ of preliminary injunction to stop the strike, which the union challenged as illegal and void.
Trial Court’s Decision:
- The trial court ruled in favor of the DBP, ordering the union to pay damages and enjoining the union from violating the CBA.
- The court dismissed the complaints against Delia P. Medina, Rodolfo Paet, and NATU.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Jurisdiction Over Labor Disputes:
- The Supreme Court reiterated that labor disputes, particularly those involving unfair labor practices, fall under the exclusive jurisdiction of the CIR, as provided under the Industrial Peace Act (Republic Act No. 875).
- The trial court’s assumption of jurisdiction over the case was erroneous, as the allegations in the complaint clearly indicated a labor dispute.
Mootness Doctrine:
- The Court applied the mootness doctrine in G.R. No. L-22584, stating that since the strike had already ended, the injunction had no further effect, and there was no need to declare it void.
Collective Bargaining Agreement:
- The Court emphasized that collective bargaining is a continuous process, and any violation of the CBA constitutes an unfair labor practice, which must be addressed by the CIR.
- The trial court’s decision to enforce the CBA and award damages was invalid due to its lack of jurisdiction.
Precedents:
- The Court relied on previous rulings, such as PAFLU vs. Tan and Republic Savings Bank vs. Court of Industrial Relations, which established that labor disputes and unfair labor practices are within the exclusive jurisdiction of the CIR.
Conclusion:
The Supreme Court dismissed the petition in G.R. No. L-22584 as moot and set aside the trial court’s decision in G.R. No. L-23083 for lack of jurisdiction. The Court reaffirmed the exclusive jurisdiction of the CIR over labor disputes and unfair labor practices, emphasizing the importance of adhering to the Industrial Peace Act and the continuous nature of collective bargaining.