G.R. No. L-16884 - National Mines and Allied Workers' Union vs. Ilao

The Court of First Instance lacks jurisdiction to issue anti-picketing injunctions related to matters pending in the Court of Industrial Relations.
All proceedings for certification elections and unfair labor practices fall under the exclusive jurisdiction of the Court of Industrial Relations.
The issuance of any injunction by the Court of First Instance in these matters is deemed unauthorized.

Temporary restraining orders must be issued following a hearing and the reception of evidence.
According to Section 9(d) of Republic Act 875, such orders are only effective for five days.
After five days, the temporary restraining order automatically becomes void by operation of law.

In 1956, the Camarines Norte Confederation of Miners and Labor Association was certified as the exclusive bargaining representative for employees of the Paracale Gumaus Consolidated Mining Company, Inc.
A closed-shop bargaining agreement was established between the Company and the Confederation, effective from January 1, 1960, to January 1, 1962.
In February 1960, the National Mines and Allied Workers' Union filed a petition for a certification election, claiming to represent the majority of employees and alleging a loss of confidence in the Confederation.

The Confederation requested the dismissal of an employee, Jorge Patinio, who was no longer a member, and the Company complied with this request.
Subsequently, the National Mines and Allied Workers' Union filed a complaint against the Company and others for unfair labor practices, alleging discriminatory actions against its members.
While these matters were pending, the Company sought an injunction from the Court of First Instance to prevent the Union from picketing and interfering with its operations.

The Court of First Instance issued a writ of preliminary injunction ex-parte, restraining the Union from interfering with the Company's labor relations.
The National Mines and Allied Workers' Union filed a petition for certiorari to annul the injunction, ...continue reading