Reyes v. Benguet Consolidated, Inc.
REITERATIONFacts
1. The Antecedents: Dominador de los Reyes was expelled from the BCI Employees and Workers Union-PAFLU, leading to the termination of his employment with Benguet Consolidated, Inc. Subsequently, he filed an unfair labor practice suit against both his former employer and the union. 2. Procedural History: The petitioner's expulsion from the union and subsequent termination from employment led to an unfair labor practice suit. During the pendency of this suit, he was denied the right to run in the union's 1971 officer elections. This denial formed the basis of his petition for certiorari to the Supreme Court. Lower courts and the Court of Industrial Relations were involved in the initial proceedings. 3. The Petition: The petitioner filed a petition for certiorari, arguing that the Court of Industrial Relations gravely abused its discretion by not allowing him to participate in the 1971 union officer elections due to the pending unfair labor practice case. The Supreme Court, after noting the lack of petitioner's participation and receiving manifestations from respondents indicating the case's mootness, required parties to comment on whether the case had become moot and academic.
Issue(s)
Whether the petition for certiorari has become moot and academic.
Ruling
The petition for certiorari is dismissed for being moot and academic.
Ratio Decidendi
On Issue 1: The Supreme Court dismissed the petition for certiorari as moot and academic. Respondents manifested that the petitioner had lost his ULP case, was validly ousted from the union, had not questioned subsequent union elections held in 1971 and thereafter, and had become the District Regional Director for Northern Luzon of a rival union, the National Mines and Allied Workers Union (NAMAWU-MIF). The Court noted the petitioner's failure to submit any comment despite being served notice of the resolution requiring manifestation on mootness. Given these supervening events, the issue of whether he should have been allowed to run in the 1971 election was rendered without practical value or use.
Main Doctrine
The Supreme Court dismissed the petition for certiorari, holding that the issue of whether the petitioner should have been allowed to run in a 1971 union election had become moot and academic. This was due to the petitioner's loss in his unfair labor practice case, his subsequent valid ouster from the union, his failure to question subsequent union elections, and his assumption of a directorship in a rival union. The Court emphasized that a case is moot when subsequent events render a resolution of the issue without practical value.