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 Confede...

Facts:

1. Certification of the Confederation:

   • In 1956, the Camarines Norte Confederation of Miners and Labor Association (Confederation) was certified as the sole and exclusive bargaining representative of all employees of the Paracale Gumaus Consolidated Mining Company, Inc. (Company).

2. Closed-Shop Agreement:

   • 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. The agreement required the Company to employ only members of the Confederation in good standing and to dismiss any employee expelled or no longer in good standing.

3. Petition for Certification Election:

   • On February 16, 1960, the National Mines and Allied Workers' Union (NMAWU) filed a petition for certification election with the Court of Industrial Relations (CIR), Bicol Branch, seeking to be certified as the sole bargaining representative of the Company's employees. NMAWU claimed it represented the majority and that the Confederation no longer did.

4. Dismissal of Jorge Patinio:

   • On March 28, 1960, the Company received a letter from the Confederation requesting the dismissal of Jorge Patinio, who was no longer a member of the Confederation. Patinio was dismissed on March 30, 1960, in accordance with the closed-shop agreement.

5. Unfair Labor Practice Complaint:

   • On April 5, 1960, NMAWU filed a complaint with the CIR, Bicol Branch, charging the Company, its general superintendent, the Confederation, and its president with unfair labor practice. The complaint cited discriminatory acts, including Patinio's dismissal.

6. Injunction Filed by the Company:

   • On April 8, 1960, the Company filed an action for injunction with the Court of First Instance (CFI) of Camarines Norte, seeking to restrain NMAWU from picketing and molesting the Company regarding the closed-shop agreement. The CFI issued a preliminary injunction ex parte the following day.

7. Petition for Certiorari:

   • NMAWU filed a petition for certiorari with the Supreme Court, seeking to annul the CFI's preliminary injunction and to prohibit the CFI from taking cognizance of the case due to lack of jurisdiction.

Issue:

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Ruling:

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Ratio:

1. Exclusive Jurisdiction of the Court of Industrial Relations:

   • The Court of Industrial Relations has exclusive jurisdiction over labor disputes, including certification elections and unfair labor practice cases. The CFI had no authority to issue an injunction related to these matters.

2. Procedural Requirements for Injunctions:

   • Under Section 9(d) of Republic Act 875, a court must hold a hearing and receive evidence before issuing an injunction in labor disputes. The CFI failed to comply with this requirement, rendering the injunction improper.

3. Temporary Restraining Orders:

   • Temporary restraining orders in labor disputes are effective for only five days and become void thereafter by operation of law.