Samahan Ng Mga Manggagawa v. Firestone Tire & Rubber Company
REITERATIONFacts
The Antecedents: The underlying dispute arose from a strike declared by the Samahan ng mga Manggagawa sa Firestone-NATU and the Firestone Filipinas Employees Association-NATU (collectively, the Union) against Firestone Tire & Rubber Company of the Philippines (the Company). The Company filed a complaint for damages with preliminary injunction against the Union and its members in the Court of First Instance of Rizal at Makati, alleging unlawful strike and picketing activities. Procedural History: The Union challenged the Court of First Instance's assumption of jurisdiction, arguing that the case involved a labor dispute concerning unfair labor practices exclusively cognizable by the Court of Industrial Relations. The Supreme Court issued a resolution requiring the Company to answer and fixed an injunction bond. Subsequently, the Supreme Court issued a writ of preliminary injunction enjoining the implementation of the trial court's restraining order against the Union's strike activities. The parties submitted memoranda, and the case was submitted for decision, with subsequent supplemental pleadings filed. The Petition: The Union filed a petition assailing the respondent judge's jurisdiction over the damages case and his issuance of a restraining order. The petition argued that the dispute was a labor dispute exclusively within the jurisdiction of the Court of Industrial Relations. Later, the respondents filed a manifestation and motion to dismiss, asserting that the petition had become moot and academic due to a settlement agreement reached before the National Labor Relations Commission (NLRC) in NLRC Case No. 0368. This agreement included the irrevocable withdrawal of the damages case filed in the Court of First Instance and the Supreme Court petition.
Issue(s)
Whether the Supreme Court's jurisdiction over the petition has become moot and academic. Whether the Court of First Instance had jurisdiction over the labor dispute.
Ruling
The Supreme Court granted the motion to dismiss and declared the case closed and terminated. The Court found that the issue of the respondent judge's jurisdiction over the case below had indeed become moot with the settlement of the strike and the respondent company's undertaking to "irrevocably dismiss" its case for damages against the petitioner union and its members. The dismissal of the case in the respondent judge's court necessarily rendered the present case moot.
Ratio Decidendi
On the issue of mootness: The Court held that the petition had become moot and academic. This was primarily due to the Order dated February 22, 1973, issued by the National Labor Relations Commission (NLRC) in NLRC Case No. 0368. This Order approved a comprehensive compromise agreement between the respondent company and the petitioner union. A crucial term of this agreement was the irrevocable withdrawal and dismissal of all cases filed by one party against the other. Specifically included in this dismissal were Civil Case No. 676-M (15023) pending with the Court of First Instance and the instant case, G.R. No. 34390, pending with the Supreme Court. The Court emphasized that this settlement had long become final and executory and had been complied with by the parties. On the issue of jurisdiction: The Court found that the question of the respondent judge's jurisdiction over the case below was rendered moot by the aforementioned settlement. Since the respondent company, as part of the compromise agreement, undertook to "irrevocably dismiss" its complaint for damages against the petitioner union and its members, the original basis for the dispute in the Court of First Instance no longer existed. Consequently, the dismissal of the case in the lower court directly led to the mootness of the present petition before the Supreme Court, which was filed to assail the lower court's jurisdiction. The Court noted that the cessation of the strike in 1972 and its settlement in 1973 further solidified the mootness of the issues, as the acts restrained by the trial court's injunction no longer existed. The Court also observed that neither party claimed damages in their respective pleadings before the Supreme Court, reinforcing the conclusion that no practical relief could be granted.
Main Doctrine
A case becomes moot and academic when the issues it seeks to resolve have already been rendered moot by subsequent events, such as a compromise agreement that resolves all the disputes between the parties and mandates the withdrawal of all related cases.