Case Digest (G.R. No. L-25003)
Facts:
This case involves Liwayway Publications, Inc. as the Plaintiff-Appellee and the Permanent Concrete Workers Union, which includes Hermogenes Atrazo, Aquilino Distor, Benjamin Gutierrez, Jose Ramos, Tiburcio Mardo, Ernesto Almario, and Domingo Leano as Defendants-Appellants. The dispute took place in Manila, and the official decision was rendered on October 23, 1981, by the First Division of the Philippine Supreme Court.
The conflict arose when Liwayway Publications, Inc., a second sublessee of part of the premises belonging to Permanent Concrete Products, Inc., faced obstruction from the defendants. On September 10, 1964, members of the union declared a strike against their employer, Permanent Concrete Products, Inc. On October 3, 1964, without legal justification, union members began to picket and block access to Liwayway's bodega, where it stored newsprint essential for its printing operations. Employees of Liwayway were threatened and physically intimidated, preventing
Case Digest (G.R. No. L-25003)
Facts:
- Background of the Parties
- Liwayway Publications, Inc. is a second sublessee occupying a portion of the premises of Permanent Concrete Products, Inc. at 1000 Cordeleria Street, Sta. Mesa, Manila.
- The plaintiff’s premises (a bodega used for storing newsprint intended for its printing and publishing business) is physically separated from the main compound of Permanent Concrete Products, Inc. by a concrete and barbed wire fence with its own distinct entrance and approach road.
- Commencement of the Dispute
- On September 10, 1964, the employees of Permanent Concrete Products, Inc.—members and representatives of the defendant Permanent Concrete Workers Union—declared a strike against their employer.
- On October 3, 1964, union members picketed and blocked the plaintiff’s truck from entering the compound to load newsprint, during which they intimidated and threatened the truck’s employees with bodily harm.
- On October 6, 1964, the union similarly blocked and prevented the general manager, personnel manager, bodega in-charge, and other employees from accessing the bodega.
- Plaintiff’s Response and Subsequent Actions
- Plaintiff made repeated demands to the defendants to desist from picketing, blockading, and threatening its employees; these demands were ignored.
- Due to the blockage, the plaintiff temporarily rented another bodega and incurred additional costs for rental and transportation of newsprint.
- Procedural History at the Court of First Instance (CFI)
- On December 14, 1964, the CFI issued a writ of preliminary injunction enjoining the defendants from:
- Threatening and intimidating the plaintiff’s executives and employees.
- Blockading or picketing the plaintiff’s compound and gate.
- Interfering with the free passage of the plaintiff’s personnel and vehicles in accessing the bodega.
- Defendants moved to dismiss the complaint on two grounds:
- The case arose from a labor dispute involving unfair labor practices, which incurs the exclusive jurisdiction of the Court of Industrial Relations.
- The plaintiff was not the real party in interest, contending that the actual cause of action should lie with the first lessee, Permanent Concrete Products, Inc.
- The lower court denied the motion to dismiss and subsequently declared the defendants in default on November 16, 1964.
- On December 16, 1964, the court refused to lift the default order and, on February 16, 1965, rendered a decision declaring permanent the writ and ordering the defendants to pay:
- The amount of P10,152.42 with interest from the commencement of the action.
- P1,000.00 as attorney’s fees and costs.
- Defendants received a copy of the decision on July 20, 1965, and filed their notice of appeal on July 26, 1965.
- On October 12, 1965, the plaintiff filed with the Supreme Court a petition for a writ of attachment on sums allegedly receivable by the union from the company, a petition which was later denied.
Issues:
- Jurisdiction of the Lower Court
- Whether the Court of First Instance (CFI) had jurisdiction to issue a writ of preliminary injunction given that the issues allegedly arose from a labor dispute involving unfair labor practices between the defendants and Permanent Concrete Products, Inc.
- Whether the involvement of Liwayway Publications, Inc.—an "innocent bystander" and sublessee—renders the dispute outside the ambit of a direct labor controversy.
- Real Party in Interest
- Whether the plaintiff, as a sublessee, is the proper party to initiate the action against the union, or if the real cause of action should be directed solely against the first lessee, Don Ramon Roces, under Article 1654 of the New Civil Code.
- Application of Labor Dispute Jurisdiction Rules
- Whether the established rules that preclude the issuance of injunctions by the CFI in labor disputes are applicable, or if the facts of the present case distinctly separate it from typical labor disputes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)