Case Digest (G.R. No. L-32216)
Facts:
National Mines & Allied Workers' Union (NAMAWUMIF) v. Honorable Gabriel V. Valero, Presiding Judge of Branch I of Court of First Instance of Camarines Norte, and Camarines Norte Mahogany Co., Inc., G.R. No. L-32216, October 23, 1984, Supreme Court Second Division, Makasiar, J., writing for the Court.
Private respondent Camarines Norte Mahogany Co., Inc. operated a log-pond and export shipping point at Mercedes, Daet, Camarines Norte. Petitioner NAMAWUMIF, through its local NAMAWU Local 206, claimed to represent dock workers and stevedores who performed loading (stevedoring) at that port. On May 20, 1970 the union requested recognition as exclusive bargaining representative and asked the company to give preference to union members; the company declined, saying it had authorized Mercedes Arrastre to do the loading.
On May 23, 1970 the union entered into an agreement with Philippine Island Arrastre, an alleged contractor of the company, recognizing the union as sole bargaining representative and setting terms and conditions of employment. On June 2, 1970 the vessel Dai Leung arrived to load the company’s logs. That same day petitioner filed a notice of strike with Region 6 of the Department of Labor and established a picket that prevented respondent company from loading the logs. Respondent company alleged daily demurrage of US$800 for delay and filed a complaint for injunction on June 3, 1970 in the former Court of First Instance (CFI) of Camarines Norte seeking to restrain petitioner from preventing the loading.
The CFI issued an ex parte preliminary injunction on June 3, 1970 enjoining the union from preventing loading of the Dai Leung; respondent company posted a P3,000 cash bond. Petitioner moved to reconsider, argued lack of notice and that the controversy was a labor dispute cognizable by the defunct Court of Industrial Relations (CIR). On June 9, 1970 respondent company sought amendment of the writ to cover any vessel; on June 18, 1970 the CFI denied petitioner's motions and modified the injunction to bar petitioner from preventing loading to any vessel during the pendency of the action.
The CFI later declared petitioner in default for failing to answer and permitted respondent company to prese...(Pro-only)
Issues:
- Did the trial court act without or in excess of jurisdiction in issuing the ex parte preliminary injunctions (procedural/due process question)?
- Was the controversy cognizable by the defunct Court of Industrial Relations (i.e., did the CIR, rather than the CFI, have jurisdiction because a l...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)