G.R. No. L-24993 - United Restauror's Employees and Labor Union vs. Torres

United Restauror's Employees & Labor Union-PAFLU (hereinafter, “the Union”) is an association of some employees of Sulo Restaurant, a lessee of Delta Development Corporation.
Delta Development Corporation (hereinafter, “Delta”) is the owner of the Makati commercial center, an establishment with thoroughfares, pedestrian lanes, and parking areas, which is leased out to various tenants.
Hon. Guillermo E. Torres, as presiding judge of Branch VIII, Court of First Instance of Rizal, is among the respondents involved through his previously rendered order.

On January 8, 1965, the Union sought Delta’s permission to conduct picketing activities on Delta’s private property surrounding the Sulo Restaurant.
Delta declined the Union’s request on January 11, 1965, citing concerns over potential liability for incidents arising out of the picketing.
Despite the denial, the Union proceeded to picket on Delta’s property on January 16, 1965.
Delta, alleging that the picketing violated its property rights and would cause irreparable injury, filed a verified complaint for an injunction, praying for a writ of preliminary injunction to “refrain from picketing on the property of plaintiff Delta Development Corporation.”

The Court of First Instance of Rizal, responding to Delta’s complaint, issued a writ of preliminary injunction ordering the Union, its attorneys, representatives, agents, and any person assisting it to refrain from picketing on Delta’s premises.
The Union, challenging the injunction, filed a motion to dismiss on January 19, 1965, contending among other grounds that:

The presiding judge exceeded his jurisdiction by issuing an injunction restricting a picketing activity arguably protected by freedom of speech.
The injunction was issued without a previous hearing and in violation of Section 9(d) of Republic Act 875.
Jurisdiction over the matter should rest with the Court of Industrial Relations, as the case involved issues of unfair labor practice under Republic Act 875.

The Union commenced an original petition for certiorari before this Court on September 18, 1965, challenging the preliminary injunction on the same grounds, while concurrently posting a bond of P1,000.00 which led to the issuance of a writ of preliminary injunction on September 29, 1965.
Delta responded to the petition on October 12, 1965, defending the validity of the injunction by arguing that:

The injunction did not enjoin the Union from picketing against the Sulo-D & E, Inc. but merely restricted its actions on Delta’s private property.
Republic Act 875 was inapplicable to an action aimed at protecting Delta’s property rights, given the absence of any employer-employee relationship between Delta and the Union members.
The injunction was issued following due hearing on January 19, 1965.

Subsequently, Delta moved to dismiss the matter as moot and academic, asserting that:

A consent election conducted by the Department of Labor on October 4, 1965, had resulted in the certification of Sulo Employees Labor Union (SELU) as the exclusive bargaining representative over the Union.
The outcome of the election stripped the Union of its standing to demand collective bargaining or continue the picketing activities.

The consent election, the result of petitions for direct certification (Case Nos. 1455-MC and 1464-MC), resulted in SELU being recognized as the exclusive representative of all employees for collective bargaining purposes.
With the majority support shifting to SELU, the Union—having lost the election—is legally deprived of the right to represent or engage in picketing as a means to compel collective bargaining with Sulo Restaurant management.

Whether the lower court had jurisdiction to issue the writ of preliminary injunction restraining the Union from conducting picketing activities on Delta’s private property.
Whether the injunction was procedurally sound given claims that it was issued without a preceding hearing and in violation of statutory provisions (i.e., Section 9(d) of Republic Act 875).

Whether the picketing, as an act of free speech and expression, was legitimately subject to judicial restraint due to encroachment on Delta’s property rights.
Whether the restriction on picketing was an appropriate balance between the constitutional right to free expression and the protection of private property.

Whether the outcome of the consent election, which resulted in SELU’s certification as the exclusive bargaining representative, renders the Union’s contention moot and academic.
Whether the Union, having lost majority support, retains any legal basis for its right to strike or picket as a mechanism to force collective bargaining.