G.R. No. 211917 - Gamaro vs. People

Petitioners are employees and laborers of the Master Shirt Company and members of the Kapisanan ng Mga Manggagawa ng Damit labor union.
Respondents are also workers of the same company but are affiliated with a rival union, the Samahan ng Mga Manggagawa sa Master Shirt Company.

On April 24, 1955, petitioners, along with other workers from the same union, protested the unjust dismissal of Amelia Sumulong by the factory management.
Following the protest, the petitioners declared a strike and established a picket line outside the factory compound.

On May 10, 1955, respondents filed a suit before the Court of First Instance of Manila seeking the issuance of a writ of preliminary injunction.
The petition alleged that non-striking employees (petitioners) were being prevented from accessing the factory for meals due to acts of coercion, violence, and obstruction by the picketing respondents.
Affidavits were submitted by respondents, detailing their claims of unlawful conduct, including intercepting food supplies and employing force and intimidation.
Based on these affidavits and the argument that without an injunction the non-striking workers would be deprived of their right to eat and potentially starve, the court issued the writ ex parte.
The injunction required the respondents to:

Refrain from obstructing the non-striking employees’ access to the factory.
Prevent any interference with the delivery of food, goods, and merchandise necessary for the employees’ livelihood.
Cease any unlawful acts previously committed or threatened.

Additionally, the court imposed a condition that petitioners post a bond of P10,000 to cover any damages that might result.

On May 11, 1955, petitioners moved to dissolve the injunction, arguing that the Court of First Instance lacked jurisdiction under Republic Act No. 875.
Republic Act No. 875 grants exclusive jurisdiction to the Court of Industrial Relations for specific labor disputes, including those involving unfair labor practices.
Both parties admitted that the acts complained of amounted to unfair labor practices, thereby implicating the exclusive jurisdiction of the Industrial Court.
Petitioners further contested that the injunction was improperly issued without adhering to the mandatory procedural requirements of Republic Act No. 875, specifically section 9(d).

The respondent court issued the injunction on the basis of affidavits and under section 6, Rule 60 of the Rules of Court instead of following the procedure laid down in section 9(d) of Republic Act No. 875.
The procedure under section 9(d) mandates a hearing with an opportunity for cross-examination to establish the facts before granting a temporary injunction, even on an ex parte basis.
Moreover, even if issued properly, an ex parte temporary restraining order is limited to a maximum effectivity of five days as per the statutory provision.

Whether the Court of First Instance had the authority to issue a writ of preliminary injunction in a labor dispute given that Republic Act No. 875 assigns exclusive jurisdiction over disputes involving unfair labor practices to the Court of Industrial Relations.

Whether the issuance of the injunction without a proper hearing and cross-examination, in contravention of the mandatory procedure under section 9(d) of Republic Act No. 875, rendered the injunction void.

Whether the ex parte nature of the injunction, granted solely on affidavit evidence, complies with the statutory requirements, especially considering that such injunctions are limited in duration (five days) by law.