G.R. No. L-25799. August 31, 1971
Union Obrera de Tabaco, Inc., et al., petitioners, vs. Hon. Perfecto Quicho, as Judge of the Court of First Instance of Albay, Floro Buenconsejo, Tirso Bonayon, and Mauro Breva, respondents.

FACTS

The case originated from an intra-union conflict within petitioner Union Obrera de Tabaco, Inc. between factions led by Tito Belangel (incumbent officers) and respondent Floro Buenconsejo. The Union’s general election, originally set for March 6, 1966, was postponed to March 1967 by a resolution approved by the Registrar of Labor Organizations. Despite this, Buenconsejo’s group proceeded to hold an election on March 6, 1966, elsewhere in Tabaco, after being denied access to the union hall by Belangel’s faction. Buenconsejo was proclaimed president. On March 8, 1966, Buenconsejo’s group filed a complaint for usurpation of organization functions (Civil Case No. 3182) in the Court of First Instance (CFI) of Albay, which issued a writ of preliminary mandatory injunction placing Buenconsejo in control of the union headquarters.
Belangel’s faction elevated the matter to the Supreme Court via certiorari and prohibition, challenging the CFI’s jurisdiction. During the pendency of this petition, supervening events occurred. A general membership meeting revoked the earlier postponement and set a new election for May 29, 1966. This election was held under the approval and supervision of the Court of Industrial Relations (CIR), where an unfair labor practice case (CIR Case No. 4052-ULP) involving the same parties was pending. The CIR subsequently approved the results of this May 29 election.

ISSUE

Whether the Court of First Instance of Albay had jurisdiction to issue the writ of preliminary mandatory injunction in an intra-union dispute involving a certified labor organization.

RULING

The Supreme Court dismissed the petition and ordered the dismissal of Civil Case No. 3182 in the CFI. The core legal logic rests on the doctrine of primary jurisdiction and the exclusivity of the Court of Industrial Relations’ authority over certified labor unions. The Court reiterated that the CIR possesses exclusive jurisdiction over controversies arising from intra-union conflicts and election-related issues involving a duly registered labor organization. The CFI, a court of general jurisdiction, lacked authority to interfere through injunctive relief in a matter inherently within the specialized competence of the industrial court.
Furthermore, the petition was rendered moot and academic by the supervening events. The dispute had been conclusively resolved by the CIR in the related unfair labor practice case, which approved the results of the May 29, 1966, union election conducted under its supervision. This CIR approval effectively settled the leadership question that was the subject of the CFI complaint. Continuing the CFI case would serve no useful purpose, as the issues had attained finality in the proper forum. The Supreme Court thus vacated the CFI’s orders for lack of jurisdiction and because the case had been overtaken by a final resolution from the competent tribunal.