Case Summary (G.R. No. L-61236)
Background and Procedural History
On March 5, 1982, the petitioner union filed a petition for direct certification as the exclusive bargaining representative of the monthly-paid employees of Zamboanga Wood Products. Subsequently, employees charged the company with underpayment of monthly living allowances. In May 1982, the union declared a strike citing illegal termination of its president, unfair labor practices, nonpayment of allowances, and issues with the employment of alien management personnel. The strike commenced on May 23, 1982. On July 9, 1982, the employer filed a complaint for damages and sought a preliminary injunction against the union officers and members, alleging obstruction of ingress and egress to its facilities.
Jurisdictional Conflict and Court Order
The respondent Judge denied the union’s motion to dismiss, ruling that the court had jurisdiction, and ordered the officers and members of the union to show cause why a preliminary injunction should not issue. The court issued a restraining order temporarily enjoining the union from obstructing the employer’s property pending the litigation.
Petitioners’ Motion and Legal Argument
Petitioners contended that the acts complained of were a lawful exercise of picketing connected with the strike and therefore fell under the exclusive jurisdiction of the Labor Arbiter pursuant to the Labor Code, specifically Batas Pambansa Blg. 227 (Labour Code as amended). They argued that the regular court lacked jurisdiction over the damage suit and the issuance of any injunction related thereto.
Supreme Court’s Temporary Restraining Order and Solicitor General’s Manifestation
Upon petition for certiorari, the Supreme Court issued a temporary restraining order against enforcing the trial court’s injunction pending resolution of the petition. The Solicitor General, in a manifestation, argued that the trial court lacked jurisdiction over the matter citing the Labor Code provisions and relevant jurisprudence, thus supporting the petitioners’ position that the exclusive jurisdiction resided with the Labor Arbiters and the National Labor Relations Commission (NLRC).
Legal Analysis on Jurisdiction: Labor Arbiter Versus Regular Court
The crux of the decision rests on Article 217 of the Labor Code (as amended by Presidential Decrees and Batas Pambansa acts) which explicitly vests original and exclusive jurisdiction over money claims and claims for damages arising from employer-employee relations to the Labor Arbiters. The Court traced the evolution of this jurisdictional scheme:
- Initially, Labor Arbiters had jurisdiction over labor disputes, including claims for damages.
- Presidential Decree No. 1367 (1978) temporarily gave courts jurisdiction over claims for moral and other damages.
- Presidential Decree No. 1691 (1980) restored exclusive jurisdiction to Labor Arbiters over money claims and damages arising from labor disputes.
- Batas Pambansa Blg. 130 (1981) reaffirmed the exclusive jurisdiction of Labor Arbiters over claims involving wages, hours, terms, conditions of employment, and damages.
The Court emphasized that jurisdiction to hear and decide such claims cannot be presumed and must be specifically conferred by law, which in this case is clearly vested in the labor arbiters, not in regular courts.
Relevant Precedents Affirming Labor Arbiter Jurisdiction
The Court cited several recent rulings reinforcing this jurisdictional rule, including:
- Pepsi-Cola Bottling Co. v. Martinez (1982), which reasserted Labor Arbiters' exclusive jurisdiction over claims for unpaid salaries, separation pay, and damages.
- Ebon v. De Guzman and Aguda v. Vallejos (both 1982), which followed the same principle.
- Older jurisprudence from the early 20th century confirming that courts must strictly apply the law as worded, deferring to the statutory grant of jurisdiction to administrative labor bodies.
Application to the Case and Ruling on Jurisdiction
The respondent Judge acted beyond his jurisdiction by entertaining the damage suit filed by the employer related to picketing during the strike, which was clearly within the exclusive domain of the Labor Arbiter. This departure from jurisdiction was contrary to the explicit mandate of Article 217 of the Labor Code.
The Court noted the incongruity of the private respondent filing the claim after clear Supreme Court rulings on the matter in early 1982 but disregarding those decisions and proceeding with the complaint in July 1982.
Policy Considerations and Administrative Competence
The Court recognized the administrative bodies’ special role in resolving labor disputes expeditiously and in accordance with the peculiarities of labor relations. Jurisdictional
...continue readingCase Syllabus (G.R. No. L-61236)
Background and Case Origin
- The case arises from a legal dispute involving the National Federation of Labor and Zambowood Monthly Employees Union (petitioners) against respondent Zamboanga Wood Products and others.
- The central legal issue is whether jurisdiction over a suit for damages filed by an employer in connection with a strike and picketing activities lies with a court or a labor arbiter.
- Respondent Judge Carlito A. Eisma, then of the Court of First Instance and now Regional Trial Court, claimed jurisdiction and denied a motion to dismiss filed by the petitioners.
- An order dated July 20, 1982 was issued by the said court requiring the union officers and members to appear for a preliminary injunction to restrain them from obstructing the employer's property access.
- This order instigated the present petition for certiorari and prohibition before the Supreme Court.
Facts Leading to Litigation
- On March 5, 1982, the petitioner union filed a petition for direct certification as sole collective bargaining representative of Zamboanga Wood Products’ monthly paid employees at its Lumayao manufacturing plant.
- On April 17, 1982, the employees charged their employer for underpayment of monthly living allowances before the Ministry of Labor and Employment (MOLE) Labor Relations Division.
- On May 3, 1982, the union served a notice of strike citing illegal termination of the union president, unfair labor practices, nonpayment of allowances, and employment of alien management without proper permits.
- The strike commenced on May 23, 1982.
- On July 9, 1982, the employer filed a complaint for damages for obstruction of private property and sought a preliminary injunction to curb the picketing activities.
- The complaint alleged blockade of the road leading to the manufacturing division, interfering with customers and suppliers.
- The petitioners filed a motion to dismiss and to dissolve the restraining order, arguing that jurisdiction over such labor disputes lay exclusively with the Labor Arbiter under Batas Pambansa Blg. 227 (Labor Code).
Proceedings in the Lower Court
- The respondent Judge denied the motion to dismiss, asserting the court’s jurisdiction.
- The court issued a temporary restraining order on July 20, 1982, restraining union members from obstructing ingress or egress to the employer’s manufacturing facilities.
- The petitioners filed a petition for certiorari and prohibition with the Supreme Court to challenge this order.
- Upon hearing the petition, the Supreme Court issued a temporary restraining order on August 5, 1982, enjoining the court and officers from enforcing the injunction or proceeding with the case until further order.
Legal Issues and Jurisdictional Question
- The pivotal issue is whether claims for damages arising from picketing or strike actions fall under the exclusive original jurisdiction of labor arbiters or the courts.
- Petitioners contend that all such labor disputes, including claims for damages connected to employer-employee relations, are within the exclusive jurisdiction of the Labor Arbiter under the Labor Code as amended.
- Respondent employer maintained that the regional trial court had jurisdiction over the damages complaint and that the injunction was not beyond its authority.
Statutory and Jurisprudential Framework
- Article 217 of the Labor Code of the Philippines and its subsequent amendments are the controlling statutes on jurisdi