Case Digest: Associated Watchmen and Security Union v. United States Line, L-10333. July 25, 1957

Labor Law | NLRC

  • United States Line, et.al. filed a complaint alleging that the petitioner Associated Watchmen and Security Union engaged in coercive picketing to force a collective bargaining agreement about watchmen's employment.
  • CFI-Manila: granted a preliminary injunction without following the requisites of Section 9 of Republic Act 875, which deals with labor disputes.
  • Respondents argued there was no employer-employee relationship and the picketing involved violence, coercion, and fraud, not peaceful protest.
WoN the trial court has jurisdiction to issue the preliminary injunction in question. NO.

The watchmen, members of petitioner union, were employed to watch and guard respondents' steamers. Although they were contracted for by watchmen agencies, the fact remains that their services were availed of and their compensation paid by the respondent agencies, even if such were done through the agencies and without the direct intervention of the steamship agencies. The relationship may not have been proximate, but this fact cannot belie the existence of the relationship of employer and employee, nor argue against the existence of a labor dispute. A labor dispute exists "regardless of whether the disputants stand in the proximate relation of employer and employee" (Section 2, Republic Act No. 875).

The existence or non-existence of a labor dispute determines the nature of the proceedings that must be followed in the issuance of an injunction. If a labor dispute exists then provisions of the Magna Carta of Labor (R. A. No. 875) should be strictly followed. On the other hand, it no labor dispute exists then the court may issue an ordinary injunction in accordance with the Rules of Court.

It is evident that a "labor dispute" existed between the watchmen, members of the petitioning union, and the steamship agencies, the respondents herein.  We find, therefore, that the court should have found that a labor dispute exists and should have proceeded in accordance with section 9 of the Republic Act No. 875 before issuing an injunction. In issuing the injunction without following the procedure outlined in said section, the court exceeded its jurisdiction.

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