National Airports Corp. v. Yanson
REITERATIONFacts
1. The Antecedents: The National Airports Corporation Employees and Laborers Association submitted a petition to the National Airports Corporation with several demands, including recognition as the sole collective bargaining agency, intervention in budget preparation and personnel actions, salary standardization, a minimum wage of P5 daily for laborers, 50% additional compensation for night shifts, and a closed shop contract. When these demands were not met, the labor union filed a petition with the Court of Industrial Relations seeking an order for the National Airports Corporation to grant all demands effective from August 16, 1949. 2. Procedural History: The National Airports Corporation moved to quash the petition before the Court of Industrial Relations, arguing that as a government agency exercising governmental functions, it could not be sued without the Republic's consent and that the Court of Industrial Relations lacked jurisdiction over its governmental functions. This motion to quash, and a subsequent motion for reconsideration, were denied. Subsequently, the National Airports Corporation filed a petition with the Supreme Court to enjoin the Court of Industrial Relations from hearing and deciding the labor union's petition, based on the same jurisdictional grounds. 3. The Petition: The National Airports Corporation filed a petition for a writ of prohibition and preliminary injunction with the Supreme Court, seeking to prevent the Court of Industrial Relations from proceeding with the labor union's petition. The petitioner argued that it is a government agency performing governmental functions and thus cannot be sued without the consent of the Republic, and that the Court of Industrial Relations lacks jurisdiction over such matters. The Supreme Court noted that the case had become moot due to the repeal of the Republic Act creating the National Airports Corporation and its abolition by Executive Order, with its functions transferred to the Civil Aeronautics Administration, another government agency that cannot be sued without consent.
Issue(s)
Whether the National Airports Corporation, as a government agency exercising governmental functions, is immune from suit before the Court of Industrial Relations. Whether the case became moot and academic due to the abolition of the National Airports Corporation.
Ruling
The petition is dismissed, without costs. The case is moot and academic due to the abolition of the National Airports Corporation and the transfer of its functions to the Civil Aeronautics Administration.
Ratio Decidendi
On Whether the National Airports Corporation, as a government agency exercising governmental functions, is immune from suit before the Court of Industrial Relations: The National Airports Corporation (NAC) is an agency of the Government of the Philippines exercising governmental functions. As such, it is immune from suit without the consent of the Republic. The Court of Industrial Relations (CIR) cannot take cognizance of the demands made upon the NAC because these are outside its jurisdiction, as provided for in section 1 in connection with section 4 of Commonwealth Act No. 103, as amended. The NAC's functions are governmental, not industrial or agricultural, which are the types of disputes generally cognizable by the CIR. Therefore, the NAC's motion to quash the petition before the CIR on grounds of governmental immunity and lack of jurisdiction was valid. On Whether the case became moot and academic due to the abolition of the National Airports Corporation: The controversy between the parties has become moot by the repeal of Republic Act No. 224, which created the National Airports Corporation, and by its abolition through Executive Order No. 365, issued on November 10, 1950. The functions, powers, and duties of the NAC were taken over by the Civil Aeronautics Administration. Even if the Supreme Court were to rule that the CIR has jurisdiction and decide the case in favor of the labor union, the decision would be unenforceable. This is because the Civil Aeronautics Administration, which now exercises the former NAC's functions, is also a government agency and may not be sued without its consent. Consequently, the case no longer presents a justiciable controversy.
Main Doctrine
The National Airports Corporation, as an agency of the Government of the Philippines exercising governmental functions, is immune from suit without the consent of the Republic. Consequently, the Court of Industrial Relations cannot take cognizance of demands made upon it, as these fall outside its jurisdiction. Moreover, the subsequent repeal of Republic Act No. 224, which created the National Airports Corporation, and its abolition by Executive Order No. 365, rendering its functions to the Civil Aeronautics Administration, rendered the case moot and academic, as any decision would be unenforceable against a government entity.