Bongat v. Bureau of Labor Relations
REITERATIONFacts
The Antecedents: Petitioners questioned the alleged grave abuse of discretion by the Bureau of Labor Relations (BLR) in issuing an Order dated June 17, 1975, which denied their appeal from a Med-Arbiter's report recommending the certification of a Collective Bargaining Agreement (CBA) between the National Association of Workers of the Philippines (NAWOP) and Quality Container Corporation (Company). NAWOP was certified as the sole and exclusive bargaining agent for the rank-and-file employees of the Company. A CBA was formulated and submitted for certification. Procedural History: Petitioners, allegedly representing 254 employees, opposed the CBA's certification, claiming they were not informed, had not ratified it, and had disaffiliated from NAWOP. NAWOP countered with a "Kapasiyahan ng Pagpapatibay ng Kasunduan" purportedly signed by 319 employees approving the CBA. Petitioners challenged the genuineness of these signatures, submitting affidavits from 138 employees stating they objected to the CBA and had disaffiliated. NAWOP submitted affidavits from its officers affirming the signatures' authenticity. Med-Arbiter Danilo P. Cruz found no adequate evidence of irregularities and recommended certification. The BLR, through Officer-In-Charge George A. Eduvala, certified the CBA on June 4, 1975, denying petitioners' appeal on June 17, 1975, stating compliance with certification requirements. The Petition: Petitioners filed a petition for certiorari with preliminary mandatory injunction, alleging grave abuse of discretion by the BLR in prematurely certifying the CBA without a full investigation, denying their appeal despite valid grounds, and deferring the inquiry into affidavit authenticity to civil courts.
Issue(s)
Whether the Bureau of Labor Relations gravely abused its discretion when it prematurely certified the CBA instead of conducting a full dress investigation considering the opposition and pending appeal, rendering the issue moot. Whether the Bureau of Labor Relations gravely abused its discretion in denying the appeal despite the existence of valid grounds, rendering the issue moot. Whether the Bureau of Labor Relations gravely abused its discretion in ordering that "any issue as to the truth of the contents of the affidavit can best be resolved in civil courts" despite its jurisdiction to make such an inquiry, rendering the issue moot.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On the issue of mootness regarding the premature certification of the CBA: The Court noted that considering the lapse of time and the fact that the three (3) year duration of the CBA had already expired on December 31, 1977, the resolution of the issues presented had become moot and academic. The prayer for a writ of mandatory injunction was deemed impossible of enforcement as there was nothing left to recall at that stage. Therefore, no useful purpose would be served by passing on the merits of the petition, as any ruling would hardly be of any practical or useful purpose. The Court reiterated the settled rule that it will not determine moot questions or abstract propositions, nor express an opinion in a case in which no practical relief can be granted, citing Central Azucarera Don Pedro vs. Don Pedro Security Union, 22 SCRA 1053. On the issue of mootness regarding the denial of the appeal: The Court noted that considering the lapse of time and the fact that the three (3) year duration of the CBA had already expired on December 31, 1977, the resolution of the issues presented had become moot and academic. The prayer for a writ of mandatory injunction was deemed impossible of enforcement as there was nothing left to recall at that stage. Therefore, no useful purpose would be served by passing on the merits of the petition, as any ruling would hardly be of any practical or useful purpose. The Court reiterated the settled rule that it will not determine moot questions or abstract propositions, nor express an opinion in a case in which no practical relief can be granted, citing Central Azucarera Don Pedro vs. Don Pedro Security Union, 22 SCRA 1053. On the issue of mootness regarding the BLR's discretion on resolving affidavit truth: The Court noted that considering the lapse of time and the fact that the three (3) year duration of the CBA had already expired on December 31, 1977, the resolution of the issues presented had become moot and academic. The prayer for a writ of mandatory injunction was deemed impossible of enforcement as there was nothing left to recall at that stage. Therefore, no useful purpose would be served by passing on the merits of the petition, as any ruling would hardly be of any practical or useful purpose. The Court reiterated the settled rule that it will not determine moot questions or abstract propositions, nor express an opinion in a case in which no practical relief can be granted, citing Central Azucarera Don Pedro vs. Don Pedro Security Union, 22 SCRA 1053.
Main Doctrine
A case becomes moot and academic when the issue presented has already expired or become impossible to enforce, rendering any ruling on the merits without practical or useful purpose.