National Union of Bank Employees vs.

Lazaro

Case

G.R. No. 56431

Ponente

SARMIENTO, J

Decision Date

Jan 19, 1988

A labor dispute between a bank union and a merged bank leads to a ruling that labor arbiters and the National Labor
Relations Commission have jurisdiction over claims for damages arising from unfair labor practices, emphasizing that civil
controversies related to labor disputes are not exclusively within the domain of the courts.

Facts:

 The case involves a labor dispute between the National Union of Bank Employees and the Commercial Bank and
Trust Company.

 On July 1, 1977, the Commercial Bank and Trust Company entered into a collective bargaining agreement with the
Commercial Bank and Trust Company Union.

 The agreement was effective until June 30, 1980, with an automatic renewal clause.

 The bank suspended negotiations with the union on May 21, 1980, after merging with the Bank of the Philippine
Islands.

 The union filed a complaint for specific performance, damages, and preliminary injunction against the private
respondents, alleging unfair labor practices and breach of contract.

Issue:

 Whether or not the courts have jurisdiction over claims for damages arising from a labor controversy.

Ruling:

 The case falls under the jurisdiction of the labor arbiters and the National Labor Relations Commission.

 The claim against the Bank of the Philippine Islands for inducing the Commercial Bank and Trust Company to violate
the collective bargaining agreement is considered an unfair labor practice, which is within the jurisdiction of the
labor department.

 The civil aspects of unfair labor practice cases, including claims for damages, are under the jurisdiction of the labor
arbiters.

Ratio:

 Jurisdiction is conferred by law and not necessarily by the nature of the action.

 Civil controversies are not exclusively within the domain of the courts.

 The fact that the Bank of the Philippine Islands was not a party to the collective bargaining agreement does not give
the court jurisdiction it does not have.

 Allowing a separate suit for the alleged tortious act would sanction split jurisdiction, which is obnoxious to the
orderly administration of justice.
  The Bank of the Philippine Islands assumed all the assets and liabilities of the Commercial Bank and Trust Company,
making it responsible for any claims or actions against the latter.

 The surviving or consolidated corporation is liable for all the obligations of the constituent corporations.

Conclusion:

 The court dismisses the case, upholding the jurisdiction of the labor arbiters and the National Labor Relations
Commission over labor disputes and claims for damages arising from unfair labor practices.

 The court affirms that civil controversies related to labor disputes are not within the exclusive domain of the courts.

 Split jurisdiction is prejudicial to the orderly administration of justice.

SUMMARY

Jurisdiction over unfair labor practice cases belongs to labor arbiters, not the
courts
The case involves a complaint filed by the National Union of Bank Employees and
the CBTC Employees Union against the Commercial Bank and Trust Company
(CBTC), Bank of the Philippine Islands (BPI), and other respondents. The complaint
alleges that the CBTC and BPI violated the existing collective bargaining agreement
during the process of renegotiation. The court states that the claim against BPI for
inducing CBTC to violate the collective bargaining agreement falls under the civil
aspect of unfair labor practice, which is under the jurisdiction of labor arbiters. The
court cites Article 247 of the Labor Code, which states that the civil aspects of all
cases involving unfair labor practices, including claims for damages, shall be under
the jurisdiction of labor arbiters. The court emphasizes that jurisdiction over unfair
labor practice cases belongs to the labor department, not the courts.

Jurisdiction is conferred by law, not by the nature of the action

The court explains that the claim for damages under Article 1314 of the Civil Code
does not automatically give the courts jurisdiction to try the damage suit.
Jurisdiction is conferred by law and not necessarily by the nature of the action. The
court states that civil controversies are not exclusive to the courts. The court also
notes that the fact that BPI was not a party to the collective bargaining agreement
does not give the court jurisdiction. The court cites a previous case, Cebu Portland
Cement Co. v. Cement Workers' Union, which held that the existence of a
controversy falling within the exclusive jurisdiction of the labor department
removes the civil case from the competence of the regular courts.

Split jurisdiction is obnoxious to the orderly administration of justice

The court emphasizes that allowing a separate suit for the alleged tortious act
committed by BPI would sanction split jurisdiction, which is an offense against the
orderly administration of justice. The court cites previous cases that upheld the
exclusive jurisdiction of the Court of Industrial Relations (CIR) in disputes involving
unfair labor practices. The court states that to rule otherwise would be prejudicial
to the orderly administration of justice. The court also notes that the fact that BPI
was not an employer at the time the act was committed does not negate the
recourse to the labor arbiter, as BPI assumed all the assets and liabilities of CBTC.

Jurisdiction of civil courts to decide money claims restored to labor arbiters

The court rejects the petitioners' reliance on Calderon v. Court of Appeals, stating
that Calderon has lost its persuasive force. The court cites subsequent rulings and
the promulgation of Presidential Decree No. 1691, which restored the jurisdiction to
decide money claims to the labor arbiters. The court concludes that the public
respondent did not act with grave abuse of discretion and dismisses the petition.