Case Digest (G.R. No. L-21212)
Facts:
Citizens' League of Freeworkers and/or Balbino Epis, Nicolas Rojo, et al. v. Hon. Macapanton Abbas, Judge of the Court of First Instance of Davao and Teofilo Geronimo and Emerita Mendez, G.R. No. L-21212, September 23, 1966, the Supreme Court En Banc, Dizon, J., writing for the Court.Petitioners are the Citizens' League of Freeworkers (a labor organization) and its member drivers; respondents are spouses Teofilo Geronimo and Emerita Mendez, owners/operators of auto-calesas in Davao City, and Hon. Macapanton Abbas, judge of the Court of First Instance (CFI) of Davao. On March 11, 1963 respondents-spouses filed Civil Case No. 3966 in the CFI seeking injunctive relief and damages, alleging that certain drivers who leased their auto-calesas (the individual petitioners) had declared a strike (February 20, 1963) and thereafter paralyzed the business through threats, intimidation and violence; the complaint prayed for an ex parte preliminary injunction restraining those acts.
On the same day, March 11, 1963, the respondent judge granted the ex parte writ of preliminary injunction but deferred action on the drivers’ motion to dissolve until March 20, 1963. On March 12, 1963 the Union filed a complaint for unfair labor practice with the Court of Industrial Relations (CIR), alleging among other grounds respondents’ refusal to bargain. On March 18, 1963 petitioners moved in the CFI to declare the writ void under Section 9(d) of Republic Act No. 875 (contending the injunction had expired after thirty days); in his March 21, 1963 order the respondent judge denied the motion, holding there was no employer-employee relationship and that the Rules of Court rather than R.A. No. 875 governed injunctions.
Petitioners then filed a petition for certiorari in the Supreme Court seeking to set aside the CFI’s writ of preliminary injunction and to restrain the respondent judge from further proceedings on the ground the controversy was a labor dispute exclusively within the CIR’s jurisdiction. The Supreme Court considered prior authorities, including Isa...(Subscriber-Only)
Issues:
- Did the Court of First Instance have jurisdiction to issue and maintain the preliminary injunction in Civil Case No. 3966 despite the existence of a labor dispute?
- Are the individual petitioners drivers operating under the boundary/lease system to be characterized as employees rather than independent lessees, thereby making the controversy a labor dispute within the exclusive jurisdiction of the Court of Industrial Relations?
- Upon filing of the unfair labor practice complaint with the Court of Industrial Relations and the passage of thirty days from issuance, should the CFI’s writ of preliminary injunct...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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