Celi v. Trajano
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the election of officers for the Equitable Bank Employees Union (EBEU). The union's constitution and by-laws mandate elections every three years. A Committee on Elections (Union Comelec) was formed to oversee the election, promulgating rules that stipulated only union members as of August 5, 1983, were qualified to vote. The election was scheduled for September 12 and 16, 1983. Petitioners, with Rogelio P. Celi as their standard bearer, and respondents, with Crestituto Gonzales as their standard bearer, were the contending parties. A significant issue arose when petitioners protested the inclusion of 41 union members who had joined after the August 5, 1983 cut-off date, specifically 35 from the Head Office and six from the Paseo de Roxas Branch. 2. Procedural History: Following the election and the protest regarding the inclusion of newly admitted members, the Union Comelec proceeded with the canvassing. Despite the protests, the Comelec did not segregate the challenged ballots. Petitioners filed a complaint with the Med-Arbiter Section of the Ministry of Labor and Employment. The Med-Arbiter, in an Order dated December 27, 1983, declared Rogelio P. Celi as the duly elected President and proclaimed other elected officers based on the COMELEC report, while dismissing the counter-protest. However, this Order was partially favorable to the petitioners. Both petitioners, seeking a recount of questioned ballots, and respondents, appealing the Med-Arbiter's Order, filed their respective motions. These were consolidated, and on March 5, 1985, the Bureau of Labor Relations (BLR) Director Cresenciano B. Trajano set aside the Med-Arbiter's Order and called for a new election, to be supervised by the National Capital Region Labor Office. Petitioners' subsequent motions for reconsideration were denied. 3. The Petition: This case is a petition for certiorari with Preliminary Injunction or Temporary Restraining Order, filed by Rogelio P. Celi and other petitioners. They seek to annul the March 5, 1985 decision of BLR Director Cresenciano B. Trajano, arguing that the Director committed grave abuse of discretion amounting to lack of jurisdiction or excess thereof by setting aside the Med-Arbiter's Order and calling for a new election. The petitioners contend that a recount or recanvassing of the disputed ballots would have resolved the claims. The Supreme Court noted that the term of office for the elected officials had likely expired and another election may have already taken place, rendering the petition moot and academic.
Issue(s)
Whether respondent Director committed a grave abuse of discretion amounting to lack of jurisdiction and/or in excess of jurisdiction in setting aside the Order of the Med-Arbiter dated December 27, 1983, and calling for a new election in his decision dated March 5, 1985. Whether the petition has become moot and academic.
Ruling
The petition is DISMISSED, the same having become moot and academic.
Ratio Decidendi
On the issue of grave abuse of discretion: The Court's resolution of the case hinges on the procedural bar of mootness, obviating the need to delve into the merits of the alleged grave abuse of discretion. On the issue of mootness: The Court observed that the election of officers of the Equitable Bank Employees Union is held every three (3) years. The last election was held in September 1983, meaning the term of office of the incumbent officers in the disputed elections had already expired. In all probability, another election must have already taken place. Therefore, the petition seeking to annul the decision calling for a new election has become moot and academic. The Court noted that private respondents had filed a comment alleging that a new election was held on July 31, 1985, supervised by the MOLE, wherein respondent Gonzales obtained a total of 185 votes for the presidency while petitioner Celi obtained only 110 votes. This subsequent event rendered the original petition moot. The Court's primary role in cases involving elections is to ensure the validity and regularity of the electoral process. When the very subject of the dispute, the election, has been superseded by a subsequent, presumably valid election, the original controversy loses its practical significance and judicial purpose. The principle of mootness dictates that courts should not pass upon questions that are already academic or have lost their controversial character. This is to avoid rendering advisory opinions on matters that no longer have any legal effect or practical consequence for the parties involved.
Main Doctrine
A petition for certiorari seeking to annul a decision calling for a new election of union officers becomes moot and academic when another election has already taken place.