Case Summary (G.R. No. 73875)
Background of the Conflict
The conflict escalated when petitioners established a picket line following their strike. In response, on May 10, 1955, the respondents sought a preliminary injunction from the Court of First Instance in Manila. They claimed that the petitioners were engaging in acts of coercion and violence that obstructed non-striking employees' rights to food and livelihood. The court, upon reviewing sworn affidavits submitted by respondents, issued the injunction without holding a prior hearing, underlining the urgency of the situation faced by the respondents.
Court's Rationale in Issuing the Injunction
The Court of First Instance justified its ruling by emphasizing the fundamental right to life and the necessity for individuals to access food. It opined that while picketing is an expression of free speech, it should not infringe upon the rights of non-striking workers. The court ordered the petitioners to cease acts that obstructed the respondents’ access to the factory and their means of sustenance, conditional upon the respondents filing a bond.
Petitioners' Challenge to the Injunction
On May 11, 1955, the petitioners filed a motion to dissolve the injunction, contesting the court's jurisdiction based on Republic Act No. 875, which vests exclusive authority over labor disputes in the Court of Industrial Relations. The respondent judge denied this motion, prompting the petitioners to seek certiorari and prohibition from the higher court, asserting that the issuance of the injunction was ultra vires.
Jurisdictional Issues Addressed
The central issue was whether the ordinary courts had jurisdiction to issue injunctions in labor disputes after the enactment of Republic Act No. 875. Precedents established that such jurisdiction lies primarily with the Court of Industrial Relations in specified labor-related cases, particularly regarding unfair labor practices, which both parties acknowledged the present dispute involved.
Procedural Validity of the Injunction
The court highlighted procedural deficiencies in the issuance of the injunction. It noted that the respondent judge issued the injunctive relief without complying with the stipulated procedures under Section 9(d) of Republic Act No. 875, which mandates a hearing with opportunities for cross-examination and cannot be granted ex parte as per the Rules of Court. This failure rendered the injunction legally void.
Duration and Nullifica
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Case Overview
- The case revolves around a labor dispute involving the Master Shirt Company, where the petitioners, employees and laborers, were members of the Kapisanan ng Mga Manggagawa ng Damit labor union.
- The conflict began on April 24, 1955, when the petitioners declared a strike following the unjust dismissal of a fellow worker, Amelia Sumulong.
- Following the strike, petitioners established a picket line outside the factory premises.
Initial Legal Action
- On May 10, 1955, a rival group of workers, affiliated with the Samahan ng Mga Manggagawa sa Master Shirt Company, filed for a writ of preliminary injunction in the Court of First Instance of Manila.
- The respondents alleged coercion and violence from the petitioners, claiming that the picket line hindered them from accessing food and their workplace.
- The Court of First Instance issued the injunction without a prior hearing, relying solely on sworn affidavits.
Court's Reasoning for the Injunction
- The court emphasized the right to life, asserting that while picketing is a form of free speech, it should not infringe upon the rights of others to access food and livelihood.
- The court ordered the petitioners to refrain from obstructing the non-strikers, ensuring that they could freely enter and exit the factory for their meals and work necessities.
Petitioners' Response
- On May 11, 1955, the petitioners filed a moti