Title
National Federation of Labor vs. Eisma
Case
G.R. No. L-61236
Decision Date
Jan 31, 1984
Union sought certification, initiated strike; company sued for damages. Supreme Court ruled Labor Arbiter, not trial court, has jurisdiction over labor dispute-related claims.

Case Digest (G.R. No. L-61236)
Expanded Legal Reasoning Model

Facts:

  • Parties and Nature of the Case
    • Petitioners: National Federation of Labor and Zambowood Monthly Employees Union, its officers and members.
    • Respondents: The Honorable Carlito A. Eisma (Judge), Lt. Col. Jacob Caruncho (Commanding Officer, Zamboanga District Command, PC, AFP), and Zamboanga Wood Products (private employer).
    • Petitioners filed a certiorari and prohibition proceeding challenging a court order requiring them to appear and show cause why a preliminary injunction should not issue to restrain them from obstructing the employer's property and premises.
    • The conflict arose from a labor dispute involving picketing and strike activities affecting Zamboanga Wood Products' manufacturing plant at Lumayao, Zamboanga City.
  • Sequence of Events
    • March 5, 1982: The National Federation of Labor filed a petition for direct certification as sole exclusive collective bargaining representative for monthly paid employees of Zamboanga Wood Products.
    • April 17, 1982: Employees charged the company for underpayment of monthly living allowances before the Ministry of Labor and Employment (MOLE).
    • May 3, 1982: The union served a strike notice citing illegal termination of its president, unfair labor practices, nonpayment of living allowances, and employment of alien management personnel without permit.
    • May 23, 1982: Strike commenced, with picketing activities involving blocking the road to the manufacturing plant.
    • July 9, 1982: Zamboanga Wood Products filed a complaint for damages and requested a preliminary injunction against the union officers and members for obstructing access to the plant.
    • Petitioners moved to dismiss the complaint, arguing that labor arbiters had exclusive jurisdiction over labor disputes, including claims for damages arising from picketing; the motion was denied by respondent Judge Eisma.
    • July 20, 1982: The court issued an order requiring the union representatives to appear and restrained them from obstructing ingress and egress to the employer’s premises.
    • August 3, 1982: This Court issued a temporary restraining order preventing the enforcement of the ex-parte injunction and enjoined respondent Judge from further proceeding with the case.
  • Jurisdictional and Procedural History
    • Respondent Judge maintained that the court had jurisdiction to hear the case for damages.
    • Solicitor General, through a manifestation in lieu of an answer, argued that labor arbiters have exclusive original jurisdiction under the Labor Code, particularly after amendments under Presidential Decrees Nos. 1367 and 1691, and Batas Pambansa Blg. 130.
    • The petition asserted that courts have no jurisdiction over damages claims arising from labor disputes and that labor arbiters are the proper tribunals under Article 217 of the Labor Code.

Issues:

  • Whether the Regional Trial Court (then Court of First Instance) has original and exclusive jurisdiction over the claim for damages filed by the employer arising from picketing and strike activities.
  • Whether the prohibition and certiorari are proper remedies to stop the Regional Trial Court from proceeding with a labor dispute involving damages and obstructive picketing activities.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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