Associated Labor Union-AFL-VIMCONTU v. Cinco
REITERATIONFacts
1. The Antecedents: The underlying dispute involved an unfair labor practice charge pending before the Court of Industrial Relations, alongside a strike and picket lines established against an employer. Concurrently, the Free Workers Association (FREEWAS) filed an action for the annulment of two collective bargaining contracts. 2. Procedural History: The Associated Labor Union-AFL-VIMCONTU (ALU) initiated a certiorari and prohibition proceeding against Judge Antonio D. Cinco, who had assumed jurisdiction over the annulment case filed by FREEWAS. ALU argued that the defunct Court of Industrial Relations possessed exclusive jurisdiction. After the respondent judge denied ALU's motion to dismiss, this petition was filed. Subsequently, both parties in the lower court case jointly moved for its dismissal, leading to an order of dismissal by Judge Cinco on January 19, 1973. Following this, ALU filed a motion to dismiss the petition before the Supreme Court, asserting that the case had become moot and academic. 3. The Petition: The petitioner, Associated Labor Union-AFL-VIMCONTU, filed a petition for certiorari and prohibition with preliminary injunction. The petition sought to prevent respondent Judge Antonio D. Cinco from proceeding with Civil Case No. R-11721, an action for annulment of collective bargaining contracts. The core argument for the petition was that the Court of Industrial Relations, not the Court of First Instance, had exclusive jurisdiction over the subject matter. However, the petition was later withdrawn by the petitioner due to the dismissal of the underlying civil case, rendering the petition moot and academic.
Issue(s)
Whether the petition for certiorari and prohibition has become moot and academic. Whether respondent Judge Antonio D. Cinco gravely abused his discretion in assuming jurisdiction over the case for annulment of collective bargaining contracts.
Ruling
The petition for certiorari and prohibition with preliminary injunction is dismissed for being moot and academic. The preliminary injunction issued is declared functus officio.
Ratio Decidendi
On Issue 1: The petition for certiorari and prohibition has become moot and academic. The petitioner sought to prevent respondent Judge Cinco from proceeding with Civil Case No. R-11721. However, the parties in that civil case subsequently filed a joint motion to dismiss the complaint, cross-claim, and counter-claim, which was granted by respondent Judge Cinco on January 19, 1973. Consequently, the petitioner itself filed a motion to dismiss the present petition on the ground that it has become moot and academic. The Court found this motion tenable, as there is no longer any live controversy to resolve regarding the jurisdiction of the respondent Judge over the dismissed civil case. On Issue 2: The issue of whether respondent Judge Antonio D. Cinco gravely abused his discretion in assuming jurisdiction over the case for annulment of collective bargaining contracts is rendered moot by the dismissal of the underlying civil case. Since the Civil Case No. R-11721 was dismissed at the instance of the parties, the question of the respondent Judge's jurisdiction over that case is no longer a live issue that this Court needs to pass upon. The preliminary injunction issued by this Court to enjoin the proceedings in the lower court is therefore functus officio, its purpose having been extinguished by the dismissal of the case it was meant to affect.
Main Doctrine
The Supreme Court dismissed a petition for certiorari and prohibition, along with the preliminary injunction previously issued, because the underlying civil case that the petition sought to enjoin had been dismissed by the parties in the lower court. This dismissal rendered the petition moot and academic, as there was no longer any judicial proceeding to prohibit or annul.