enjoin

Facts:
The case involves the Social Security System Employees Association
(SSSEA) and the Social Security System (SSS). The SSS filed a
complaint for damages and a prayer for a writ of preliminary injunction
against the SSSEA, alleging that the union staged an illegal strike and
barricaded the entrances to the SSS building. The SSS argued that the
employees of the SSS, being government employees, are not allowed
to strike and may be enjoined by the Regional Trial Court (RTC) from
continuing with their strike.

Issue:
The main issues raised in this case are: 1) whether the employees of
the SSS have the right to strike, and 2) whether the RTC has
jurisdiction to hear the case and enjoin the strikers from continuing
with the strike.

Ruling:
The Supreme Court ruled that government employees, including those
in the SSS, are prohibited from striking by express provision of
Memorandum Circular No. 6 series of 1987 of the Civil Service
Commission and as implied in Executive Order No. 180. While the
Constitution recognizes the right of government employees to self-
organization, it does not explicitly include the right to strike. The Court
also noted that the terms and conditions of employment in the
government are governed by law, and employees therein shall not
strike for the purpose of securing changes in their terms and
conditions of employment.

The Court further held that the RTC has jurisdiction to enjoin the strike
and order the strikers to return to work. The Labor Code provides that
the terms and conditions of employment of government employees
shall be governed by the Civil Service Law, rules, and regulations.
Additionally, Executive Order No. 180 vests the Public Sector Labor-
Management Council with jurisdiction over unresolved labor disputes
involving government employees. Therefore, the National Labor
Relations Commission (NLRC) does not have jurisdiction over the
dispute, and the RTC is the appropriate venue for the issuance of a
writ of injunction.

Ratio:
The court held that government employees, including those of
government-controlled corporations, are covered by the prohibition
against strikes. The terms and conditions of employment in the
government are fixed by law, and the legislature and administrative
heads of government determine these terms and conditions. The
principle of labor unionism in the private sector, which allows strikes
and collective bargaining, does not apply to government employees.
Instead, government employees may negotiate for improvements in
their terms and conditions of employment that are not fixed by law.
The court also clarified that the NLRC does not have jurisdiction over
labor disputes involving government employees, and the Public Sector
Labor-Management Council does not have the authority to issue writs
of injunction. Therefore, the Regional Trial Court had jurisdiction to
issue the injunction in this case.

Summary:
This case involves a strike staged by employees of the SSS, a
government-controlled corporation. The court held that government
employees, including those of government-controlled corporations, are
covered by the prohibition against strikes. The terms and conditions of
employment in the government are fixed by law, and government
employees cannot use the same weapons employed by workers in the
private sector to secure concessions from their employers. The court
also clarified that the NLRC does not have jurisdiction over labor
disputes involving government employees, and the Public Sector
Labor-Management Council does not have the authority to issue writs
of injunction. Therefore, the Regional Trial Court had jurisdiction to
issue the injunction in this case.