Case Digest (G.R. No. L-16884)
Facts:
- In 1956, the Camarines Norte Confederation of Miners and Labor Association was certified as the exclusive bargaining representative for employees of Paracale Gumaus Consolidated Mining Company, Inc.
- A closed-shop agreement was signed on December 19, 1959, effective from January 1, 1960, to January 1, 1962, requiring employment only for members in good standing of the Confederation.
- On February 16, 1960, the National Mines and Allied Workers' Union filed a petition for a certification election, claiming to represent the majority of employees and alleging loss of confidence in the Confederation.
- The Confederation requested the dismissal of Jorge Patinio, an employee who was no longer a member, and the Company complied on March 30, 1960.
- On April 5, 1960, the National Mines and Allied Workers' Union filed a complaint against the Company and others for unfair labor practices, citing Patinio's dismissal as discriminatory.
- The Company sought an injunction on April 8, 1960, to prevent the Union from picketing and interfering with its closed-shop agreement, leading to a writ of preliminary injunction issued by the Court of First Instance of Camarines Norte.
- The National Mines and Allied Workers' Union filed a petition for certiorari against the injunction, claiming lack of jurisdiction by the Court of First Instance.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Court of First Instance of Camarines Norte lacked jurisdiction over the subject matter of Civil Case No. 1207, rendering the ex-parte preliminary injunction void.
- Even if jurisdiction existed, the issuance of the pre...(Unlock)
Ratio:
- The Supreme Court highlighted that labor disputes, including certification elections and unfair labor practices, fall under the exclusive jurisdiction of the Court of Industrial Relations.
- The presence of two pending proceedings in the Court of Industrial Relations meant the Court of First Instance could not issue an injunction related to those matt...continue reading
Case Digest (G.R. No. L-16884)
Facts:
In 1956, the Camarines Norte Confederation of Miners and Labor Association, a legitimate labor union, was certified as the sole and exclusive bargaining representative for all employees of the Paracale Gumaus Consolidated Mining Company, Inc., a domestic corporation based in Gumaus, Paracale, Camarines Norte. On December 19, 1959, the Company entered into a closed-shop bargaining agreement with the Confederation, effective from January 1, 1960, to January 1, 1962. This agreement mandated that only members in good standing of the Confederation would be employed, and any employee expelled or deemed to have lost good standing would be dismissed. On February 16, 1960, the National Mines and Allied Workers' Union, another labor organization, filed a petition for a certification election with the Court of Industrial Relations, claiming to represent the majority of the employees and alleging that the Confederation no longer had their confidence.
On March 28, 1960, the Confederation requested the dismissal of an employee, Jorge Patinio, who was no longer a member. The Company complied and dismissed Patinio two days later. Subsequently, on April 5, 1960, the National Mines and Allied Workers' Union filed a complaint against the Company, its general superintendent G. M. Budiselic, the Confederation, and its president Fermin Lapuz, alleging unfair labor practices, particularly citing Patinio's dismissal as discriminatory. On April 8, 1960, while the certification election and unfair labor practice complaint were pending, the Company filed an action for injunction in the Court of First Instance of Camarines Norte, seeking to restrai...