San Miguel Corporation Employees Union Philippine Transport and General Workers Organization v. Calleja
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the election of officers for the San Miguel Corporation Employees Union (SMCEU). The union's last election was held in December 1981, with a three-year term for elected officials. A petition for a new election was filed on December 2, 1984, by the union itself, seeking to replace officers whose terms were expiring. 2. Procedural History: The case has a complex procedural history involving multiple elections, restraining orders, appeals, and petitions. An initial election scheduled for December 1984 was suspended. Subsequent attempts to hold elections were delayed by legal challenges, including disputes over the union's name (SMCEU vs. SMCEU-PTGWO) and the qualification of candidates. The case was remanded from the Supreme Court to the Bureau of Labor Relations (BLR) and Med-Arbiter multiple times. An election was finally set for September 15, 1987, then rescheduled to October 5, 1987, after a motion to reconsider the date was granted. Petitioners filed an election protest after the October 5, 1987 election, which was dismissed. This dismissal was appealed to the Supreme Court (G.R. No. 82183) and subsequently denied. 3. The Petition: The petitioners, officers of the San Miguel Corporation Employees Union-PTGWO, filed this petition for certiorari on October 17, 1987, seeking to set aside the orders calling for the election of union officers on October 5, 1987, nullify the election if held, and restrain its enforcement. They argue that the public respondents acted with grave abuse of discretion by setting the election without a proper petition and by denying them due process. They also sought to hold the respondents in contempt for proceeding with actions despite court orders. The petition was filed after the election had already taken place and winners were proclaimed, rendering injunctive relief moot.
Issue(s)
Whether the public respondents acted with grave abuse of discretion amounting to lack of jurisdiction in setting the local election on October 5, 1987, and whether the petitioners were deprived of due process of law. Whether the petitioners' actions constituted trifling with proceedings, rendering the case moot. Whether the public respondents should be held in contempt of court for proceeding with the election.
Ruling
The petition is dismissed for lack of merit.
Ratio Decidendi
On the issue of grave abuse of discretion and due process: The contentions of the petitioners are without merit. The petitioners themselves filed the petition praying for the conduct of an election to select union officers. By filing the petition, they necessarily affirmed that the petition was sufficient in form and substance. Therefore, they are estopped from claiming that the petition did not meet legal requirements. Regarding their claim of denial of due process, the records show that they were given their day in court, and their motion for reconsideration/appeal was duly considered. The mere fact that their motion was denied does not mean they were denied due process of law. The public respondents accommodated Hipolito repeatedly, and after the signing of the Collective Bargaining Agreement, another pre-election conference was called. The Med-Arbiter issued an order setting the election, and petitioners filed a motion for reconsideration, which was subsequently followed by a manifestation requesting a rescheduled date. This manifestation was acted upon by the Med-Arbiter, setting aside the original date and allowing parties to agree on a new one, or for the Representation Officer to fix it. This demonstrates that petitioners were given ample opportunity to be heard and to participate in the proceedings. On the issue of trifling with proceedings and mootness: The case is a clear instance of trifling with judicial and quasi-judicial proceedings. Petitioners filed a petition for election, then turned around and claimed their petition was not proper and sought to nullify the election in which they participated and lost. They filed an election protest with the Med-Arbiter and, without waiting for its resolution, filed the instant petition for certiorari. Subsequently, they elevated the dismissal of their election protest to this Court via another petition for certiorari (G.R. No. 82183), which was denied. Both petitions sought the nullification of the same election. The Court noted that the winners in the election were proclaimed and sworn into office on November 11, 1987, prior to the temporary restraining order issued by this Court on December 9, 1987. Thus, the act intended to be restrained was already a fait accompli. Since the act sought to be restrained had already been consummated, injunction or restraining order does not lie. Moreover, it does not appear that petitioners are entitled to the main relief sought, so there is no legal justification for a restraining order or preliminary injunction. On the issue of contempt: The records show that a temporary restraining order was issued on December 9, 1987, enjoining respondents from proclaiming the alleged winners. However, the winners were already proclaimed and sworn into office on November 11, 1987, by virtue of an order dated November 6, 1987, of the Med-Arbiter in the election protest filed by petitioners. Therefore, the act intended to be restrained was already a fait accompli. Accordingly, the public respondents have not violated any order of this Court which would make them guilty of contempt.
Main Doctrine
A petition for certiorari seeking to nullify an election that has already been conducted and consummated, especially when the petitioners participated in the election and subsequently filed an election protest, may be dismissed for being moot and academic, and for constituting trifling with judicial proceedings. Furthermore, parties who initiate or participate in proceedings cannot later claim that such proceedings lacked legal requirements or that they were denied due process when their own actions led to the situation.