The Supreme Court in Eduardo J. Mariño, Jr. v. Gil Gamilla addressed the issue of whether a Regional Trial Court (RTC) has jurisdiction over a dispute involving access to a union office when an intra-union conflict is already pending before the Department of Labor and Employment (DOLE). The Court ruled that while the RTC lacked jurisdiction to issue an injunction regarding access to the office due to the ongoing labor dispute, it did have jurisdiction over the claim for damages arising from the alleged tortious act of padlocking the office. This distinction clarifies the boundaries between labor disputes and civil actions, providing guidance on where such cases should be litigated. The decision underscores the importance of adhering to the principle of primary jurisdiction, while also recognizing the right to seek damages for civil wrongs in the appropriate forum.

Padlocked Doors and Jurisdictional Battles: Who Holds the Key to Union Office Access?

The heart of this case lies in a conflict within the UST Faculty Union (USTFU), which led to a physical lockout from the union office. The petitioners, Mariño and Alamis, sought legal recourse when respondents, Gamilla, Aseron, and Cardenas, allegedly padlocked the USTFU office, preventing their access. This action occurred amidst an ongoing intra-union dispute regarding the legitimacy of union leadership. The central legal question is whether the RTC had jurisdiction to issue an injunction and award damages, considering the labor dispute already before the DOLE.

The Court of Appeals (CA) sided with the respondents, stating that the RTC lacked jurisdiction because the issue of office access was inextricably linked to the intra-union dispute. It cited Article 254 of the Labor Code, which prohibits injunctions in cases “involving or growing out of labor disputes.” However, the Supreme Court disagreed in part, clarifying the scope of labor disputes and the jurisdiction of regular courts over civil actions for damages.

The Supreme Court began its analysis by distinguishing between labor disputes and intra-union disputes. A labor dispute, as defined in Article 212(l) of the Labor Code, encompasses controversies concerning terms and conditions of employment or the representation of persons in negotiating those terms. This jurisdiction falls under the Labor Arbiters and the National Labor Relations Commission (NLRC). On the other hand, an intra-union dispute involves conflicts among union members, arising from violations of the union’s constitution and by-laws, which falls under the Bureau of Labor Relations (BLR).

In this case, the Supreme Court emphasized that the RTC’s jurisdiction is determined by the allegations in the complaint and the nature of the relief sought. The petitioners’ complaint sought both an injunction to remove the padlocks and damages for the respondents’ actions. The Court acknowledged the principle of adherence of jurisdiction, which dictates that once a court or tribunal acquires jurisdiction, it retains it until the case is resolved. The Court stated:

It is a settled rule that jurisdiction, once acquired, continues until the case is finally terminated.

Because the issue of legitimacy was pending with the Med-Arbiter, the RTC should not have exercised jurisdiction over the prayer for injunction. This aligned with the principle that the resolution of the right to access the union office was intertwined with the question of who the legitimate officers were, a matter already under the DOLE’s purview. The High Court referenced the case of UST Faculty Union, et al. v. Bitonio, Jr., et al., which had already ruled the October 4, 1996, election void due to irregularities.

However, the Supreme Court diverged from the CA’s ruling on the matter of damages. It explained that while the BLR has jurisdiction over intra-union disputes, it is not specifically empowered to award damages arising from such disputes, unlike the NLRC in employer-employee relations. The Court noted that Article 241 of the Labor Code contemplates the separate institution of criminal and civil actions in regular courts for violations of union membership rights, and that:

Where no employer-employee exists between the parties and no issue is involved which may be resolved by reference to the Labor Code, other labor statutes, or any collective bargaining agreement, it is the regional trial court that has jurisdiction.

The Court thus distinguished between the remedies sought by the petitioners, clarifying that the claim for damages based on the alleged tortious act of padlocking the office falls within the jurisdiction of the regular courts. The claim for damages did not arise from the Labor Code or any labor relations statute. It was rooted in civil law, specifically the alleged tortious conduct of the respondents. As such, the RTC had the authority to hear and decide the claim for damages.

This ruling underscores the principle that administrative agencies, like the BLR, have limited jurisdiction, confined to the powers granted by their enabling statutes. While specialized tribunals offer expertise in specific areas, they should not deprive regular courts of their power to decide ordinary cases under general laws. The Supreme Court clarified that the claim for damages was based on the respondents’ alleged tortious conduct, placing it squarely within the realm of civil law and, therefore, within the jurisdiction of the regular courts.

The Supreme Court’s decision provides a balanced approach, recognizing the DOLE’s jurisdiction over intra-union disputes while preserving the right to seek damages in regular courts for civil wrongs. This ensures that individuals are not left without a remedy for damages suffered due to tortious acts, even when those acts occur within the context of a labor dispute.

FAQs

What was the key issue in this case?	The main issue was whether the Regional Trial Court (RTC) had jurisdiction over a dispute involving access to a union office when an intra-union conflict was already pending before the Department of Labor and Employment (DOLE).
What did the Court rule regarding the RTC’s jurisdiction over the injunction?	The Court ruled that the RTC lacked jurisdiction to issue an injunction regarding access to the office because the issue was intertwined with the ongoing intra-union dispute before the DOLE.
Did the Court find that the RTC had jurisdiction over any part of the case?	Yes, the Court held that the RTC had jurisdiction over the claim for damages arising from the alleged tortious act of padlocking the union office, as this claim was based on civil law.
What is the difference between a labor dispute and an intra-union dispute?	A labor dispute concerns terms and conditions of employment or representation in negotiating those terms, while an intra-union dispute involves conflicts among union members arising from violations of the union’s constitution and by-laws.
What is the principle of adherence of jurisdiction?	The principle of adherence of jurisdiction dictates that once a court or tribunal acquires jurisdiction over a case, it retains that jurisdiction until the case is fully resolved.
Why did the Court distinguish between the remedies sought by the petitioners?	The Court distinguished between the injunction and the claim for damages to determine which tribunal had the proper jurisdiction over each remedy, based on the nature of the claim and the relevant laws.
What is the significance of Article 241 of the Labor Code in this case?	Article 241 contemplates the separate institution of criminal and civil actions in regular courts for violations of union membership rights, which supported the Court’s finding that the RTC had jurisdiction over the damages claim.
What was the Court’s ruling in UST Faculty Union, et al. v. Bitonio, Jr., et al. and how did it affect this case?	The Court in UST Faculty Union, et al. v. Bitonio, Jr., et al. ruled that the October 4, 1996, election was void due to irregularities, which supported the finding that the issue of legitimate union leadership was already resolved.

In conclusion, the Supreme Court’s decision in Eduardo J. Mariño, Jr. v. Gil Gamilla clarifies the jurisdictional boundaries between labor tribunals and regular courts in cases involving both labor disputes and civil claims. While the DOLE has primary jurisdiction over intra-union conflicts and related injunctive reliefs, regular courts retain jurisdiction over civil actions for damages arising from tortious conduct. This decision offers guidance to litigants and ensures that appropriate remedies are available in the proper forum.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: EDUARDO J. MARIÑO, JR. VS. GIL GAMILLA, G.R. NO. 132400, January 31, 2005