National Sugar Workers Union-PAFLU v. Martinez
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a petition for certification elections filed by the Associated Labor Union (ALU) claiming majority representation among the workers at Central Azucarera De La Carlota. The National Sugar Workers Union-PAFLU (NASWU-PAFLU) was the other contending union. Both parties agreed on the bargaining unit and eligible voters, leading to an order for certification elections. 2. Procedural History: The Court of Industrial Relations (CIR) initially ordered the certification elections. ALU filed a motion for reconsideration and a motion to suspend the elections, which led the CIR en banc to suspend the elections. Subsequently, the CIR en banc denied ALU's motion for reconsideration and lifted the suspension. The Department of Labor scheduled the elections, which were reset upon ALU's request. Despite a pending motion to suspend addressed to the CIR en banc, the Presiding Judge issued an order on April 11, 1967, allowing the elections but deferring the canvassing of results. 3. The Petition: This petition for certiorari and prohibition seeks to overturn the April 11, 1967 order by Judge Arsenio I. Martinez, alleging grave abuse of discretion for deferring the canvassing of election results contrary to a CIR en banc resolution. The petition argues that the canvassing should not have been deferred, especially as the election returns had been submitted. However, the Supreme Court later dismissed this petition as moot and academic due to a prior resolution in a related case (G.R. No. L-27382) that ordered the counting of ballots and reported the results, the abolition of the CIR, and the passage of time without further action from the parties.
Issue(s)
Whether respondent Presiding Judge committed grave abuse of discretion when he issued the controverted order dated April 11, 1967. Whether the petition has become moot and academic.
Ruling
The petition is dismissed for being moot and academic. No costs.
Ratio Decidendi
On the issue of grave abuse of discretion: The Court held that the issue of whether the respondent Presiding Judge committed grave abuse of discretion in issuing the controverted order dated April 11, 1967, had become moot and academic due to a resolution by the Supreme Court on May 19, 1967, in G.R. No. L-27382, which ordered the counting of ballots and reporting of results in certification elections. On the issue of the petition becoming moot and academic: The petition in G.R. No. L-27382 was dismissed for being moot and academic, considering the lapse of time, the lack of further action by the management and employees, and the subsequent abolition of the Court of Industrial Relations itself. Therefore, for the same reasons, the present petition was also dismissed as moot and academic.
Main Doctrine
A petition for certiorari and prohibition questioning an order regarding the canvassing of certification election results is dismissed for being moot and academic when the Supreme Court has already ordered the counting of ballots and the issue has been rendered moot by subsequent events, including the abolition of the Court of Industrial Relations.