G.R. No. 128661 - Philippine National Bank vs. Court of Appeals

The case arises from allegations that on or about February 19, 1976, in the Municipality of Pasig, Rizal, certain officers and/or members of the Philippine Association of Free Labor Unions (PAFLU), specifically of the Luzano Faction, and who were also laborers of the Philippine Blooming Mills Company, Inc., engaged in unauthorized and unlawful activities.
The accused were charged with staging or declaring a strike by establishing picket lines in front of the factory, which resulted in a work stoppage, paralysis of various operations, and damage to the factory’s business interests.

The criminal case was instituted in the Court of First Instance of Rizal, Branch VI, based on an information alleging that the act of picketing constituted a criminal offense arising from an illegal strike.
Petitioners challenged the jurisdiction of the court, arguing that the filing of the information was premature given that the labor dispute had not been fully resolved by the appropriate labor dispute resolution bodies.

There was a pending labor dispute before the National Labor Relations Commission (NLRC), which the petitioners contended had a prejudicial effect on the criminal proceedings.
The petitioners emphasized that the resolution of the labor dispute should first be determined by the NLRC and the Secretary of Labor, as provided by the then-applicable Presidential Decrees—PD No. 823 and its amendatory PD No. 849—before any criminal charges could be appropriately pursued.

Presidential Decree No. 823 (1975) declared a general prohibition on strikes, picketing, and lockouts, establishing the policy framework for labor relations during that period.
Presidential Decree No. 849 (1975) amended PD No. 823, specifically recognizing that certain strikes, particularly those in vital industries, were deemed illegal unless proper certification procedures were followed.
The Decrees provided that any unauthorized strike, without resolving economic issues in collective bargaining through proper channels — namely, certification by the President or his authorized representative to the NLRC — was automatically enjoined.

The information primarily alleged that the criminal liability of the petitioners arose from their involvement in setting up picket lines.
Petitioners contended that peaceful picketing is a form of protected free expression, as recognized in previous case law, and that the action taken against them was an undue criminalization of an exercise of a constitutional right.

Whether the Court of First Instance of Rizal had jurisdiction to entertain a criminal suit arising from an alleged illegal strike when there was a pending labor dispute before the National Labor Relations Commission.
Whether the filing of the criminal information by the fiscal was premature due to the failure to exhaust or defer to the jurisdictional requisites established by the applicable Presidential Decrees.

Whether the criminal action against the petitioners, based on their involvement in picketing, was legally appropriate given that the labor dispute had yet to be resolved by the proper labor dispute resolution bodies.
Whether the acts committed, which involved picketing and not necessarily violence or coercion, could be separated from the constitutional protection accorded to peaceful picketing under freedom of speech.

How the amendment under PD No. 849 and subsequent legislative enactments (e.g., Batas Pambansa Blg. 227) impacted the criminal liability for the acts charged.
Whether the penal provisions of PD No. 823 as amended by PD No. 849 were still enforceable in light of later legal developments protecting peaceful picketing and limiting criminal sanctions in labor disputes.