National Federation of Labor vs. Eisma

Labor arbiters have exclusive original jurisdiction over claims for damages arising from picketing or a strike, stripping regular courts of jurisdiction over such matters under Article 217 of the Labor Code.

Petitioner National Federation of Labor sought certification as the exclusive collective bargaining representative of the monthly paid employees of private respondent Zamboanga Wood Products, Inc. at its manufacturing plant in Lumbayao, Zamboanga City. The union and the company became embroiled in labor disputes, including allegations of unfair labor practices and illegal termination, culminating in a strike. The statutory backdrop involves successive amendments to Article 217 of the Labor Code, which shifted jurisdiction over money claims and damages between labor arbiters and regular courts before finally vesting it in labor arbiters.

Petitioner National Federation of Labor, on March 5, 1982, filed a petition with the Ministry of Labor for direct certification as the sole exclusive collective bargaining representative of the monthly paid employees of Zamboanga Wood Products, Inc. at its Lumbayao plant. The following month, the employees charged the firm before the same office for underpayment of monthly living allowances. On May 3, 1982, the union filed a notice of strike alleging illegal termination of the local union president, unfair labor practices, non-payment of living allowances, and employment of oppressive alien management personnel. A strike vote was taken, with 79 voting yes and 3 voting no, and the strike commenced on May 23, 1982.

On July 9, 1982, Zamboanga Wood Products filed a complaint for damages against the union's officers and members in the Court of First Instance, alleging that the defendants blockaded the road leading to its manufacturing division, preventing customers and suppliers from accessing the premises. Six days later, the union filed a motion to dismiss, arguing that the acts complained of were incidents of picketing during a strike and that jurisdiction belonged exclusively to the Labor Arbiter under Batas Pambansa Blg. 227. The trial court denied the motion and issued an order requiring the union officers and members to show cause why a writ of preliminary injunction should not be issued, while temporarily restraining them from obstructing the company's use of its property. This prompted the union to elevate the matter to the Supreme Court via certiorari and prohibition.

• Jurisdiction: Petitioners contended that the acts complained of were incidents of picketing by employees on strike against the private respondent, and that exclusive jurisdiction over the dispute belongs to the Labor Arbiter pursuant to Batas Pambansa Blg. 227, not to a court of first instance.

• Jurisdiction: Private respondent sustained the original jurisdiction of the respondent Judge and maintained that the order complained of was not in excess of such jurisdiction or issued with grave abuse of discretion.
• Solicitor General's Manifestation: The Solicitor General, representing public respondents, answered in the negative regarding the lower court's jurisdiction, stating that the petition had merit and should be given due course, tracing the amendments to the Labor Code that vested jurisdiction in labor arbiters.

• Jurisdiction: Whether a court of first instance (now Regional Trial Court) or a labor arbiter has jurisdiction over a suit for damages filed by an employer arising from picketing that accompanied a strike.

• Jurisdiction: No. The labor arbiter possesses exclusive original jurisdiction over claims for damages arising from picketing or a strike, not a court of first instance or regional trial court.

• Jurisdiction: Article 217 of the Labor Code explicitly vests exclusive original jurisdiction in labor arbiters over money claims of workers and all other claims arising from employer-employee relations. The legislative history confirms this: while Presidential Decree No. 1367 temporarily excluded labor arbiters from awarding moral and other forms of damages, Presidential Decree No. 1691 and Batas Pambansa Blg. 130 restored and clarified this jurisdiction, vesting it back in labor arbiters. The Court emphasized that the first duty of courts is to apply the law as worded. Since the suit for damages arose from picketing during a strike—an incident of employer-employee relations—it falls squarely within the labor arbiter's jurisdiction. Any deviation from this express statutory command cannot be tolerated.

• Jurisdiction of Labor Arbiters — Under Article 217 of the Labor Code, as amended, labor arbiters have exclusive original jurisdiction over all money claims of workers and all other claims arising from employer-employee relations, including claims for damages arising from picketing or a strike. The Court applied this by nullifying the trial court's order for lack of jurisdiction, emphasizing that regular courts act beyond their authority when entertaining such suits.
• Application of the Law — The first and fundamental duty of courts is to apply the law as worded; construction and interpretation come only after it has been demonstrated that application is impossible or inadequate without them. The Court relied on this principle from Lizarraga Hermanos vs. Yap Tico to enforce the explicit statutory grant of jurisdiction to labor arbiters.

• "The first and fundamental duty of courts, in our judgment, is to apply the law. Construction and interpretation come only after it has been demonstrated that application is impossible or inadequate without them." — This passage articulates the Court's rationale for strictly applying the explicit statutory provisions of Article 217 without need for interpretation.
• "Increasingly, this Court has been committed to the view that unless the law speaks clearly and unequivocally, the choice should fall on [an administrative agency]." — This reflects the jurisprudential trend of favoring administrative bodies over regular courts in labor matters, unless the law explicitly states otherwise.

• Pepsi-Cola Bottling Co. vs. Martinez, L-58877, May 15, 1982, 112 SCRA 578 — Controlling precedent followed. The Court held that the Labor Arbiter has exclusive jurisdiction over claims for damages arising from employer-employee relations, applying Presidential Decree No. 1691.
• Lizarraga Hermanos vs. Yap Tico, 24 Phil. 504 (1913) — Cited for the doctrine that the primary duty of courts is to apply the law as written before resorting to construction or interpretation.
• Garcia vs. Martinez, L-47629, August 3, 1978, 84 SCRA 577 — Cited to show the application of the original wording of Article 217 which vested jurisdiction in labor arbiters.
• Bengzon vs. Inciong, L-48706-07, June 29, 1979, 91 SCRA 248 — Cited alongside Garcia for the same proposition regarding labor arbiter jurisdiction.

• Article 217, Labor Code of the Philippines — As amended by Presidential Decree No. 1691 and Batas Pambansa Blg. 130, this provision vests labor arbiters with original and exclusive jurisdiction over all money claims of workers and all other claims arising from employer-employee relations. The Court applied this to divest the trial court of jurisdiction over the employer's damage suit.
• Batas Pambansa Blg. 227, Section 6 (amending Article 265 of the Labor Code) — Prohibits persons engaged in picketing from committing acts of violence, coercion, or intimidation, or obstructing free ingress to or egress from the employer's premises. The Court noted this provision in the context of the union's right to peaceful picketing.

Teehankee, Makasiar, Aquino, Guerrero, Melencio-Herrera, Plana, Escolin, Relova, and Gutierrez, Jr., JJ., concurred. Abad Santos, J., concurred and expressed the hope that Art. 217 should not undergo repeated amendments. Concepcion Jr., J., took no part. De Castro, J., is on leave.