National Waterworks & Sewerage Authority v. Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The National Waterworks and Sewerage Authority (NAWASA) faced a situation where two labor unions, KKMK-NWSA and KKMK-NWSA-PAFLU, both sought to renegotiate the collective bargaining contract that had expired. To prevent industrial unrest, NAWASA filed a petition for a certification election to determine the appropriate bargaining representative for its rank-and-file employees. 2. Procedural History: NAWASA filed a petition for certification election with the Court of Industrial Relations (CIR) on May 29, 1970, while also expressing doubt about the CIR's jurisdiction over a public corporation performing governmental functions. One union, KKMK-NWSA-PAFLU, moved to dismiss the petition, citing lack of jurisdiction, prior judgment, and failure to state a cause of action. The other union, KKMK-NWSA, supported NAWASA's petition. On August 19, 1970, the CIR dismissed the petition without prejudice due to the alternative stance of NAWASA regarding its governmental functions. A motion for reconsideration was denied by the CIR en banc on February 1, 1971. This led to the current petition for certiorari by NAWASA. 3. The Petition: NAWASA filed a petition for certiorari with the Supreme Court, seeking review of the CIR's resolution dismissing its petition for a certification election. The petition raised the issue of the CIR's jurisdiction over public corporations performing governmental functions. However, the Supreme Court noted that the present Labor Code has abolished the CIR, rendering the case moot and academic. The Court also referenced prior rulings indicating that the CIR did possess jurisdiction over labor disputes involving government-owned corporations, even when exercising governmental powers.
Issue(s)
Whether the respondent Court of Industrial Relations possessed jurisdiction over a public corporation exercising governmental functions. Whether the petition for certification election was rendered moot and academic by subsequent legal developments.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On the issue of jurisdiction over public corporations exercising governmental functions: The Court noted that no decision on the merits was necessary. The present Labor Code expressly abolished the respondent Court of Industrial Relations. In DBP Employees Union-NATU v. Development Bank of the Philippines, it was held that the legal situation had radically changed with the new Labor Code, which abolished the CIR and replaced it with the National Labor Relations Commission. Therefore, any decision on the merits would be purely academic. However, the Court made a passing mention that in Philippine Virginia Tobacco Administration vs. CIR, it was ruled that notwithstanding the exercise of governmental powers, the CIR still possessed jurisdiction over labor disputes involving government-owned corporations. On the issue of the petition being moot and academic: The abolition of the Court of Industrial Relations by Presidential Decree No. 442 (Labor Code) rendered the case moot and academic. The Court cited DBP Employees Union-NATU v. Development Bank of the Philippines where it was held that the radical change in the legal landscape due to the new Labor Code made any decision on the merits of the case academic. The existence of a new Labor Code and the replacement of the CIR with the National Labor Relations Commission meant that the original forum no longer existed. Consequently, the Court found it unnecessary and inadvisable to rule on the merits, as any such ruling would be in the nature of an advisory opinion.
Main Doctrine
A petition for certiorari seeking review of a resolution dismissing a petition for certification election is rendered moot and academic by the abolition of the Court of Industrial Relations under the new Labor Code.