GR L 30174; (May, 1972) (Digest)
G.R. No. L-30174 May 31, 1972
Cebu Portland Cement Co., plaintiff-appellant, vs. Cement Workers’ Union, et al., defendants-appellees.
FACTS
Cebu Portland Cement Company filed a complaint in the Court of First Instance of Cebu against the Cement Workers’ Union and thirteen individuals. The company alleged that the defendants staged a strike on March 25, 1961, at its Naga, Cebu plant, establishing pickets on private property and committing acts of violence causing injury and damage. The complaint sought a declaration that the strike was illegal, the dismissal of its organizers, and the award of actual and exemplary damages totaling significant daily sums. The company also applied for a preliminary injunction to halt the picketing.
The defendants opposed the injunction, asserting that the Court of Industrial Relations (CIR) had exclusive jurisdiction because an unfair labor practice charge had been filed against the company on March 25, 1961. They contended the strike arose from the company’s refusal to enter into an agreed-upon collective bargaining contract. The lower court, noting the labor dispute had even been certified by the President to the CIR, sustained the defendants and dismissed the civil case for lack of jurisdiction.
ISSUE
Whether the Court of First Instance had jurisdiction over the civil case for damages arising from the strike, or if jurisdiction resided exclusively with the Court of Industrial Relations.
RULING
The Supreme Court affirmed the dismissal, holding that jurisdiction was vested exclusively in the Court of Industrial Relations. The legal logic is anchored on the principle that jurisdiction is conferred by law based on the nature of the controversy, not by the sequence of filing cases. The appellant’s claim for damages was inextricably linked to the determination of the strike’s legality. This central issue was, in turn, interwoven with the unfair labor practice charge alleging the company’s refusal to bargain collectivelyβa matter indisputably within the exclusive domain of the CIR.
The Court rejected the appellant’s argument that the CIR had not yet acquired jurisdiction because only a charge, not a formal complaint, had been filed. Jurisdiction of the CIR is determined by the existence of a labor dispute falling under its exclusive authority, not by the procedural stage of any case. Furthermore, the Presidential certification of the dispute to the CIR itself conferred exclusive jurisdiction on that court over the entire controversy and all connected matters. Consequently, the regular courts were divested of authority to adjudicate the civil action for damages, as it arose out of and was connected to an industrial dispute under the CIR’s exclusive cognizance.
