Case Digest (G.R. No. L-17838)
Facts:
Nasipit Labor Union (MFL) v. Court of Industrial Relations, Nasipit Stevedoring Co., Inc., and Olivio G. Ruiz, G.R. No. L-17838. August 03, 1966, the Supreme Court En Banc, Ruiz Castro, J., writing for the Court.The petitioner is Nasipit Labor Union (MFL); respondents are the Court of Industrial Relations, Nasipit Stevedoring Co., Inc., and Olivio G. Ruiz (respondent Ruiz was the company president). On October 2, 1958 the union and the stevedoring company executed a collective bargaining agreement (CBA) containing, among other provisions, a clause that the company "shall only employ union members" for its stevedoring work and an allocation scheme with another union. The record later shows allegations that the company induced the union to file for disaffiliation from the Mindanao Federation of Labor (MFL), that the union’s certificate of registration was briefly revoked and then reinstated, and that certain union members were deprived of stevedoring work beginning March 1959.
Before the complaint to the CIR, related litigation was filed in the Court of First Instance (CFI) of Agusan. On March 5, 1959 the Nasipit Labor Union and Cipriano Malonzo filed civil case No. 699 in the CFI seeking reformation of the CBA; that suit was dismissed March 25, 1959 for loss of interest. On September 7, 1959 the Nasipit Labor Union together with the Mindanao Federation of Labor (styled NASLU‑MFL) filed civil case No. 748 in the CFI against the company, Olivio Ruiz, and the Young Men Labor Union Stevedores (YMLUS) for enforcement of the CBA, damages, and a preliminary mandatory injunction; that CFI action was pending when the union later went to the CIR.
On March 22, 1960 the Nasipit Labor Union (without MFL) filed with the Court of Industrial Relations complaint No. 2175‑ULP alleging unfair labor practice (ULP), claiming coercion and bad faith bargaining by the company, deprivation of work of listed members, and seeking orders to desist, back wages and an order to bargain in good faith. The respondents answered and moved to dismiss on two grounds: (1) another action between the same parties and for the same cause was pending in the CFI of Agusan, and (2) the CIR lacked jurisdiction to hear a suit to enforce a collective bargaining agreement.
The CIR granted the motion to dismiss in an order dated September 8, 1960, relying on prior Supreme Court authority (notably Philippine ...(Pro-only)
Issues:
- Did the Court of Industrial Relations have jurisdiction to entertain the union’s complaint (case No. 2175‑ULP) alleging unfair labor practice and seeking enforcement of the collective bargaining agreement?
- Were the CIR’s dismissal and finding that the union’s ULP allegations were not bona fide but a forum‑shif...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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