Philippine Charity Sweepstakes Employees Assn.-Paflu v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The underlying dispute involved a petition for mandamus filed by the Philippine Charity Sweepstakes Employees Association-PAFLU and other employees against the Court of Industrial Relations (CIR) and the Philippine Charity Sweepstakes Office. The petitioners sought to compel the CIR to act on an urgent petition for the issuance of a preliminary mandatory injunction that had been pending for over four months. Procedural History: The petitioners filed an urgent petition for a preliminary mandatory injunction with the CIR. After a significant delay, the CIR had not yet acted on this petition. Consequently, the petitioners filed a petition for mandamus with the Supreme Court to compel the CIR to issue a ruling. The Supreme Court required the respondents to comment, and only the Philippine Charity Sweepstakes Office filed a response, arguing the case was moot. The Petition: The petition before the Supreme Court was a writ of mandamus seeking to compel the Court of Industrial Relations to rule on a pending urgent petition for a preliminary mandatory injunction. The petitioners argued that the CIR's failure to act on the injunction request for over four months necessitated judicial intervention. However, during the pendency of the mandamus petition, the CIR en banc issued a resolution on May 26, 1972, which affirmed a prior order denying the preliminary mandatory injunction, rendering the mandamus petition moot and academic.
Issue(s)
Whether the petition for mandamus has become moot and academic. Whether the Court of Industrial Relations acted with undue delay in resolving the motion for reconsideration.
Ruling
The petition is declared moot and academic. Without pronouncement as to costs.
Ratio Decidendi
On Whether the petition for mandamus has become moot and academic: The petition for mandamus sought to compel the respondent Court of Industrial Relations (CIR) to act on an urgent petition for a preliminary mandatory injunction. However, while the mandamus case was pending before the Supreme Court, the CIR en banc issued a Resolution on May 26, 1972, which affirmed the denial of the preliminary mandatory injunction. This action by the CIR rendered the original prayer in the mandamus petition functus officio, as the act sought to be compelled had already been performed. Consequently, the petition for mandamus had become moot and academic. The Court noted that the petitioners failed to candidly inform the Supreme Court of this subsequent resolution by the CIR en banc, which was a significant development. On Whether the Court of Industrial Relations acted with undue delay in resolving the motion for reconsideration: Although the petition was moot, the Court found it necessary to admonish the respondent Court of Industrial Relations. The CIR, being a special court tasked with the effective implementation of labor laws, has an affirmative and dynamic function that requires promptness and dispatch. The Court cited its own ruling in Ang Tibay v. Court of Industrial Relations, emphasizing that the CIR is not a passive entity but is expected to act with celerity. The undue delay in resolving the urgent motion for a preliminary mandatory injunction, which led to the filing of the mandamus petition, demonstrated a failing on the part of the CIR. Such delays are detrimental to the rights of labor and can erode public confidence in the effectiveness of the tribunal. The Court expressed the expectation that the CIR would exert greater care in the future to avoid similar situations that necessitate further proceedings before the Supreme Court.
Main Doctrine
A petition for mandamus compelling a court to act on a motion becomes moot and academic once the court has subsequently acted on the motion, even if the action taken is adverse to the petitioner. However, the court's delay in acting on the motion warrants admonition.