Primary Holding
The Court of Industrial Relations retains jurisdiction over matters incidental to a case already pending before it, even where the immediate dispute involves only one laborer, because the jurisdiction of the court had already attached in the original case and the right sought to be enforced springs from the decision in that case. The dismissal of a single laborer does not divest the court of jurisdiction where the motion for reinstatement is, in essence, a part of the original case and seeks enforcement of the court's prior judgment.
Background
The San Miguel Brewery, Inc. (SMB) was a corporate employer subject to the jurisdiction of the Court of Industrial Relations under Commonwealth Act No. 103. The National Labor Union and the San Miguel Brewery Employees and Laborers Association were labor organizations representing the workers of SMB. The parties had previously entered into a stipulation, incorporated into a decision of the Court of Industrial Relations, that there should be no dismissal, suspension, or transfer of laborers except for just cause. This stipulation formed the backdrop against which subsequent disputes over employee discipline and reinstatement were to be resolved.
History
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SMB filed a petition in Case No. 271-V before the Court of Industrial Relations against the National Labor Union and San Miguel Brewery Employees and Laborers Association, seeking resolution of, among other matters, demand No. 4 regarding dismissal, suspension, or transfer of laborers.
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Court of Industrial Relations, Sept. 17, 1949 — rendered a decision providing that there should be no dismissal, suspension, or transfer except for just cause, and finding the transfers of Nocos, De Guzman, and Tapiador valid and justified.
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July 1950 — The National Labor Union and San Miguel Brewery Employees and Laborers Association filed a motion in Case No. 271-V seeking reinstatement of Santos Ortiz and punishment for contempt; an amended motion was later filed solely on behalf of the National Labor Union and docketed as Case No. 478-V, assigned to the Second Branch.
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Court of Industrial Relations, Second Branch — denied SMB's motion to dismiss, holding that the case was closely connected with Case No. 271-V and that jurisdiction had already attached in that case.
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SMB appealed to the Supreme Court by way of petition for certiorari, which affirmed the order of the Court of Industrial Relations with costs against the petitioner.
Facts
The San Miguel Brewery, Inc. (SMB) filed a petition in Case No. 271-V before the Court of Industrial Relations against the National Labor Union and the San Miguel Brewery Employees and Laborers Association, seeking resolution of, among other matters, demand No. 4, which provided that no dismissal, suspension, or transfer should be made except for just cause, and that Julian Nocos, Hermogenes de Guzman, and Lazaro Tapiador, who had been dismissed or transferred without cause, be reinstated. On September 17, 1949, the Court of Industrial Relations rendered a decision. Both parties agreed that there should be no dismissal, suspension, or transfer except for just cause, and the only conflict regarding this demand referred to the transfer of Nocos, Guzman, and Tapiador. The respondents alleged that the transfers were effected because these three men were responsible for the filing of the petition against the rotation system contemplated by SMB.
SMB, in justification of its stand, presented evidence that the Coca-Cola Plant was formerly operating on three shifts with two bottling lines; that one additional bottling line was installed and the operation was reduced to two shifts with three bottling lines; that as a consequence, the personnel working in one of the shifts were reassigned to the additional bottling line, with the exception of the crew of one of the shifts of the syrup room, because two crews of syrup men were adequate to feed all three bottling lines; and that for this reason, the transfer of Nocos, De Guzman, and Tapiador was found to be absolutely necessary. The Court of Industrial Relations found that the transfers were accomplished for no other purpose than that stated in SMB's evidence, and that this purpose was valid and justified.
On April 15, 1950, SMB dismissed Santos Ortiz allegedly for cause. The National Labor Union and San Miguel Brewery Employees and Laborers Association filed a motion in July 1950 in Case No. 271-V praying for the reinstatement of Santos Ortiz on the ground that he was dismissed without any just cause and for his union activities, in violation of the decision of September 17, 1949, and for the punishment of contempt of the person responsible for the dismissal. SMB questioned the authority of Atty. Eulogio R. Lerum to file the motion in the name of the San Miguel Brewery Employees and Laborers Association, alleging that the latter had disauthorized Atty. Lerum and was already dissolved. Before the matter could be acted upon, Atty. Lerum filed an amended motion on behalf solely of the National Labor Union, reiterating the same allegations, which was docketed as Case No. 478-V and assigned to the Second Branch.
SMB filed a motion to dismiss, alleging that the case involved only one laborer and therefore did not come within the jurisdiction of the Court of Industrial Relations, there being no dispute involving more than thirty laborers as provided by Section 4 of Commonwealth Act No. 103. The Court of Industrial Relations denied the motion, holding that the case was so closely connected with Case No. 271-V between the same parties that the court must, of necessity, acquire jurisdiction over it, considering that the jurisdiction of the court had already attached in Case No. 271-V. The court further noted that the dissolution of "SAMBELA" was not pertinent to the issues involved, the amended motion having been brought in the name of the National Labor Union solely and singly, of which Ortiz was an active member.
Arguments of the Petitioners
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Lack of Jurisdiction: Petitioner argued that the Court of Industrial Relations had no jurisdiction to entertain the amended motion docketed as Case No. 478-V because it dealt with a dispute over the propriety of the dismissal of only one laborer, Santos Ortiz, and therefore did not involve more than thirty laborers as required by Section 4 of Commonwealth Act No. 103.
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Improper Assignment to Second Branch: Petitioner argued that even if the motion were held to be a mere incident of Case No. 271-V, the First Branch of the Court of Industrial Relations should have jurisdiction over it, inasmuch as Case No. 271-V was originally assigned to and disposed of by said Branch.
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Lack of Authority of Counsel: Petitioner assailed the authority of the National Labor Union to represent Santos Ortiz in view of the dissolution of the San Miguel Brewery Employees and Laborers Association, which was formerly affiliated with the Union.
Arguments of the Respondents
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Continuing Jurisdiction: Respondent Court of Industrial Relations held that the case was so closely connected with Case No. 271-V between the same parties that the court must, of necessity, acquire jurisdiction over it, considering that the jurisdiction of the court had already attached in Case No. 271-V.
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Enforcement of Prior Decision: Respondent National Labor Union maintained that the amended motion merely sought the reinstatement of Santos Ortiz by virtue and as a consequence of the decision of September 17, 1949 in Case No. 271-V, and that the right sought to be enforced sprang from the decision in said case.
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Interest of the Union: Respondent argued that under Section 17 of Commonwealth Act No. 103, the Court of Industrial Relations may, on application of an interested party, and after due hearing, alter, modify, or set aside any decision, or reopen any question involved therein, and that the National Labor Union and Santos Ortiz were certainly interested parties within the meaning of the law.
Issues
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Jurisdiction Over Single-Laborer Dispute: Whether the Court of Industrial Relations had jurisdiction to entertain the amended motion seeking reinstatement of Santos Ortiz, a single laborer, where the motion sought to enforce a prior decision in Case No. 271-V.
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Authority of Counsel and Effect of Union Dissolution: Whether the dissolution of the San Miguel Brewery Employees and Laborers Association affected the authority of the National Labor Union to represent Santos Ortiz or the jurisdiction of the Court of Industrial Relations.
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Assignment to Second Branch: Whether the assignment of the amended motion to the Second Branch of the Court of Industrial Relations was valid where Case No. 271-V was originally assigned to and disposed of by the First Branch.
Ruling
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Jurisdiction Over Single-Laborer Dispute: Yes. The Court of Industrial Relations had jurisdiction to entertain the amended motion because the right sought to be enforced sprang from the decision in Case No. 271-V, and the amended motion was, in essence, a part of that case. The Court of Industrial Relations may reopen any question involved in its decision at any time during its effectiveness under Section 17 of Commonwealth Act No. 103.
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Authority of Counsel and Effect of Union Dissolution: Yes. The National Labor Union and Santos Ortiz were interested parties within the meaning of Section 17 of Commonwealth Act No. 103, and the dissolution of the San Miguel Brewery Employees and Laborers Association should not affect the jurisdiction already acquired by the Court of Industrial Relations.
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Assignment to Second Branch: Yes. The assignment of the amended motion to the Second Branch was made by the Presiding Judge in pursuance of Section 1 of Commonwealth Act No. 103, as amended, and a court composed of several branches is deemed to be a totality.
Ruling Rationale
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Jurisdiction Over Single-Laborer Dispute: The decision in Case No. 271-V provided, upon stipulation of the parties, that there should be no dismissal, suspension, or transfer except for just cause, and this pronouncement included all the laborers employed by the petitioner and then represented by the National Labor Union and the San Miguel Brewery Employees and Laborers Association. Santos Ortiz was one such laborer. The amended motion merely sought his reinstatement by virtue and as a consequence of the decision of September 17, 1949. The amended motion, in essence, was a part of Case No. 271-V, as the right sought to be enforced sprang from the decision in that case. Under Section 17 of Commonwealth Act No. 103, the Court of Industrial Relations may reopen any question involved in its decision at any time during its effectiveness. To adopt the theory of the petitioner that the dismissal of Santos Ortiz should be the subject-matter of an independent case would frustrate the purposes of the law that created the Court of Industrial Relations. Furthermore, the Court of Industrial Relations has all the inherent powers of a court of justice provided in paragraph 5 of Rule 124 of the Rules of Court, among which is the power to compel obedience to its judgments, orders, and process, as well as the power to punish direct and indirect contempts. Section 23 of Commonwealth Act No. 103 expressly specifies that in case of non-compliance with any award, order, or decision of the Court of Industrial Relations after it has become final, conclusive, and executory, the judgment may be enforced by a writ of execution or any other remedy provided by law. The Court of Industrial Relations, in entertaining the motion, was merely called upon to enforce its decision of September 17, 1949, and the execution and enforcement of said decision must necessarily and conveniently be sought and disposed of in the same case.
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Authority of Counsel and Effect of Union Dissolution: Under Section 17 of Commonwealth Act No. 103, the Court of Industrial Relations may, on application of an interested party, and after due hearing, alter, modify in whole or in part, or set aside any decision, or reopen any question involved therein. The National Labor Union, and even Santos Ortiz for that matter, were certainly interested parties within the meaning of the law. The dissolution of the San Miguel Brewery Employees and Laborers Association should not affect the jurisdiction already acquired by the Court of Industrial Relations. Citing Mortera vs. The Court of Industrial Relations, the Court noted that when petitioners appeared for the first time before the Court of Industrial Relations as members of the Bisig Ng Canlubang (NLU), they appeared as workers of the Canlubang Sugar Estate, and when they seceded from said union to form another, they remained workers of the Canlubang Sugar Estate. The splitting of workers into two unions cannot affect the jurisdiction of the court, and even a complete dissolution of the union would not affect the court's jurisdiction. Otherwise, approval would be given to a scheme by which a workers' union, in case of an adverse decision, may always make a mockery of orders and decisions of the court, a result against the administration of justice and violative of the principles and purposes of Commonwealth Act No. 103.
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Assignment to Second Branch: The assignment of the amended motion to the Second Branch was made by the Presiding Judge in pursuance of Section 1 of Commonwealth Act No. 103, as amended, which provides that the Judges shall act on such matters as the Presiding Judge may designate, and each of them shall have power to preside over the hearing of cases assigned to him and to render decisions thereon. It is an established doctrine that a court, though composed of several branches, is deemed to be a totality. Citing Mercado vs. Ocampo, 72 Phil. 318, the Court upheld the act of one branch regarding an order of another branch of a court of first instance, holding that a judge presiding over one branch of a court of first instance may modify or annul an order issued by another judge of the same court without infringing the principle of coordination, and the reason for this doctrine is simply that both judges act in the same court and it is the same court that has modified or annulled the order.
Doctrines
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Continuing Jurisdiction of the Court of Industrial Relations — Once the Court of Industrial Relations acquires jurisdiction over a case, it retains jurisdiction over all matters incidental to or connected with that case, including motions seeking enforcement of its decisions. The jurisdiction of the court over an amended motion is the same jurisdiction over the original case, and the court may reopen any question involved in its decision at any time during its effectiveness under Section 17 of Commonwealth Act No. 103.
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Totality of a Court Composed of Several Branches — A court, though composed of several branches, is deemed to be a totality. A judge presiding over one branch of a court may modify or annul an order issued by another judge of the same court without infringing the principle of coordination, because both judges act in the same court and it is the same court that has modified or annulled the order.
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Effect of Union Dissolution on Jurisdiction — The dissolution of a labor union does not affect the jurisdiction already acquired by the Court of Industrial Relations. Otherwise, approval would be given to a scheme by which a workers' union, in case of an adverse decision, may always make a mockery of orders and decisions of the court, a result against the administration of justice and violative of the principles and purposes of Commonwealth Act No. 103.
Key Excerpts
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"Said amended motion in essence can be said to be a part of case No. 271-V, as the right sought to be enforced springs from the decision in said case. At any rate, the Court of Industrial Relations may reopen any question involved at the decision at any time during its effectiveness under section 17 of Commonwealth Act No. 103. To adopt the theory of the petitioner that the dismissal of Santos Ortiz should be the subject-matter of an independent case, (to be ventilated in an ordinary court of justice), would be to frustrate in a way the purposes of the law that created the Court of Industrial Relations." — This passage articulates the core ratio decidendi: the amended motion was an incident of the original case, and the court's continuing jurisdiction permitted it to entertain the motion.
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"It follows from this provisions that the Court of Industrial Relations, in entertaining the motion of the respondent Union as regards the dismissal of Santos Ortiz, is merely called upon to enforce its decision of September 17, 1949 in case No. 271-V. The execution and enforcement of said decision must necessarily and conveniently be sought and disposed of in the same case." — This passage establishes that the motion was essentially an enforcement proceeding, which must be disposed of in the same case where the decision was rendered.
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"The members of the Canlubang workers Union may even dissolved the union completedly but that would not affect the jurisdiction of the court. Otherwise, approval will be given to the scheme by which a workers' union, in case of an adverse decision of the Court of Industrial Relations, may always make a mockery of orders and decision of said court. Such a result is against the administration of justice and is violative of the principles and the purposes of which Commonwealth Act. No. 103 was enacted." — This passage, quoted from Mortera vs. The Court of Industrial Relations, establishes the doctrine that union dissolution does not divest the court of jurisdiction.
Precedents Cited
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Mortera vs. The Court of Industrial Relations, 45 Off. Gaz. 1714 — Cited as controlling precedent for the proposition that the dissolution of a labor union does not affect the jurisdiction of the Court of Industrial Relations, and that workers who appear before the court as members of a union remain workers of the employer regardless of union affiliation.
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Mercado vs. Ocampo, 72 Phil. 318 — Cited as controlling precedent for the doctrine that a court composed of several branches is deemed to be a totality, and that a judge of one branch may modify or annul an order issued by another judge of the same court.
Provisions
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Section 1, Commonwealth Act No. 103 — Provides that the Judges of the Court of Industrial Relations shall act on such matters as the Presiding Judge may designate, and each of them shall have power to preside over the hearing of cases assigned to him and to render decisions thereon. Applied to validate the assignment of the amended motion to the Second Branch.
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Section 4, Commonwealth Act No. 103 — Provides for the jurisdiction of the Court of Industrial Relations over disputes involving more than thirty laborers. Cited by the petitioner to challenge jurisdiction, but the Court held that the amended motion was an incident of a case where jurisdiction had already attached.
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Section 17, Commonwealth Act No. 103 — Provides that the Court of Industrial Relations may, on application of an interested party, and after due hearing, alter, modify in whole or in part, or set aside any decision, or reopen any question involved therein. Applied to support the court's continuing jurisdiction over the amended motion.
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Section 23, Commonwealth Act No. 103 — Provides that in case of non-compliance with any award, order, or decision of the Court of Industrial Relations after it has become final, conclusive, and executory, the judgment may be enforced by a writ of execution or any other remedy provided by law. Applied to show that the court was merely enforcing its prior decision.
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Paragraph 5, Rule 124, Rules of Court — Provides that courts have inherent powers to compel obedience to their judgments, orders, and process, as well as the power to punish direct and indirect contempts. Applied to support the court's authority to entertain the motion for reinstatement and contempt.
Notable Concurring Opinions
Feria, Pablo, Bengzon, Tuason, Montemayor, Reyes, and Bautista Angelo, JJ., concurred.