Lakas ng Manggagawang Pilipino v. Benguet Consolidated, Inc.
REITERATIONFacts
The Antecedents: Petitioner, Lakas ng Manggagawang Pilipino, filed a motion for intervention in a pending certification proceeding before respondent Judge Amando C. Bugayong. Respondent Judge issued an order setting a consent election without including petitioner as a participant, and subsequently denied petitioner's motion to intervene. Procedural History: Petitioner's motion for reconsideration could not be acted upon due to the respondent Judge's absence and court recess. Consequently, petitioner filed a petition for certiorari and prohibition with preliminary injunction before the Supreme Court, which issued a temporary restraining order. Later, the Benguet Consolidated, Inc. Employees and Workers Union-Paflu intervened in the Supreme Court proceedings. The Petition: Petitioner sought to compel its admission as a party intervenor in the representation proceedings before the Court of Industrial Relations (CIR) to participate in the selection of a bargaining agent. Subsequently, petitioner filed a motion to dismiss the case, stating that its objective could now be attained as two other contending unions had expressed conformity to its inclusion as an intervenor.
Issue(s)
Whether the Supreme Court should dismiss the petition for certiorari and prohibition with preliminary injunction. Whether the Court of Industrial Relations (CIR) has discretion in conducting certification elections and allowing intervention.
Ruling
The Supreme Court granted the motion to dismiss filed by petitioner Lakas ng Manggagawang Pilipino. The Court ruled that the case had become moot as the objective of the petitioner, which was to be admitted as an intervenor in the certification proceeding, could now be attained due to the conformity of other contending unions to its inclusion.
Ratio Decidendi
On the dismissal of the petition: The Court found the motion to dismiss to be well-founded. The ultimate objective of the petition was to compel the admission of the petitioner as a party intervenor in representation proceedings before the CIR. The petitioner's motion to dismiss indicated that this objective could now be attained because two other contending unions, the National Mines and Allied Workers Union and the Benguet Mine Workers Union, had expressed their conformity to the inclusion of the petitioner as an intervenor. Therefore, the case had become moot, and there was no longer any necessity for the Supreme Court to pass upon the merits of the petition. The opposition to the motion to dismiss, filed by the intervenor union, was deemed bereft of legal support. On the discretion of the CIR in certification elections: The Court reiterated its long-standing policy of recognizing a latitude of discretion in the Court of Industrial Relations (CIR) in assuring that certification elections are properly conducted. This discretion is vested in the CIR as the agency best positioned to oversee such proceedings. The fundamental principle is that every labor organization should be afforded an opportunity in a free and honest election to prove its claim as the exclusive collective bargaining representative. The Court cited previous decisions, including LVN Pictures, Inc. v. Philippine Musicians Guild, which characterized certification proceedings not as litigation but as a non-adversary, fact-finding investigation. The assertion by the intervenor union that the case should proceed to enrich jurisprudence was deemed insufficient to deny the motion to dismiss, especially when the legal issues raised were considered to lack significance.
Main Doctrine
A motion to dismiss a petition for certiorari and prohibition with preliminary injunction, filed by a petitioner seeking intervention in a certification proceeding before the Court of Industrial Relations, should be granted when the objective of compelling the admission of the petitioner as an intervenor can be attained due to the conformity of other contending unions to its inclusion, thereby rendering the case moot.