Case Summary (G.R. No. L-23537)

Prematurity of the Petition for Certiorari

• A petition for certiorari and prohibition is considered premature if filed before the lower court has resolved a motion for reconsideration regarding a previously issued injunction.
• If the petitioner has other available remedies in the lower court and has availed of them, certiorari will not be an appropriate remedy.

Jurisdiction Based on Allegations in the Complaint

• Jurisdiction is conferred upon the court by the allegations in the complaint, not by assertions made in a motion for reconsideration.
• The mere claim of a labor dispute in a motion does not automatically strip the court of its jurisdiction if the complaint indicates no employer-employee relationship exists.

Erroneous Orders Within Jurisdiction

• Orders or decisions made by a court that has jurisdiction over the subject matter cannot be corrected by certiorari, even if they are deemed irregular or erroneous.
• The court's jurisdiction allows it to make decisions on all questions pertaining to the case.

Background of the Case

• Katipunan Lumber Co., Inc. operates with a permanent staff and engages independent contractors for occasional work.
• Cirilo Cabasa had a contract with Katipunan to supply labor, which he terminated, leading Roque Abellar to enter a similar contract with Katipunan.
• Katipunan filed a complaint for injunction and damages against Mendoza, Seno, and the Associated Labor Union, alleging illegal interference in their contractual obligations.

Issuance of Preliminary Injunction

• The court issued a preliminary injunction to prevent the defendants from interfering with Katipunan's operations, contingent upon the posting of a bond.
• The defendants filed a motion for reconsideration, arguing the court lacked jurisdiction and that peaceful picketing could not be enjoined.

Petition for Certiorari Filed Prematurely

• Petitioners filed a petition for certiorari and prohibition without waiting for the resolution of their motion for reconsideration, claiming the case involved a labor dispute.
• The court noted that the petition was premature as the lower court had not yet resolved the jurisdictional issues.

Respondents' Motion for Dismissal

• Respondents filed a motion to dismiss the petition, asserting it was premature and that the determination of jurisdiction depended on evidence to be presented in court.
• The lower court deferred its resolution on the motion for reconsideration until evidence was presented.

Developments in the Lower Court

• The lower court ordered a pre-trial to expedite the hearing of the case, indicating that the issues needed to be joined for a proper resolution.
• Respondents argued that the petitioners had already availed themselves of remedies in the lower court, rendering the petition moot.

Jurisdiction and Allegations of Labor Dispute

• The primary issue was whether the lower court had jurisdiction based on the allegations in the complaint.
• The court found that the allegations of damages and lack of an employer-employee relationship c...continue reading

Case Syllabus (G.R. No. L-23537)

Background of the Case

• Respondent Katipunan Lumber Co., Inc. (Katipunan) operates in the lumber business.
• It employs a regular and permanent staff, including office employees, drivers, and laborers affiliated with the Cebu Industrial Labor Organization (CILO).
• For occasional work, Katipunan hires independent labor contractors, with compensation based on work performed.
• Cirilo Cabasa had a contract with Katipunan to provide labor for non-routine tasks, which he sought to terminate on August 18, 1964.
• Roque Abellar entered a contract with Katipunan to supply labor following Cabasa's termination.
• On September 3, 1964, Katipunan and Abellar filed a complaint for Injunction and Damages against Mendoza, Seno, and the Associated Labor Union (ALU) in the Court of First Instance (CFI) of Cebu.

Allegations in the Complaint

• The complaint detailed alleged illegal interference by the respondents with Katipunan's contractual obligations with Abellar.
• It asserted there was no employer-employee relationship between Katipunan and Abellar's laborers.
• The plaintiffs claimed that their business was suffering from harassment, threats, and coercion from the defendants.

Court Orders and Proceedings

• On September 8, 1964, Judge Modesto R. Ramolete issued an order granting a preliminary injunction, contingent upon the filing of a P50,000 bond.
• The injunction restrained the defendants from:
  • Blocking or disturbing Abellar's trucks.
  • Disturbing or molesting Abella...continue reading