Villarosa v. Trajano
REITERATIONFacts
The Antecedents: Petitioners sought the annulment of an Order and Resolution of the Bureau of Labor Relations (BLR) that decreed the holding of an election for officers of the Ilaw at Buklod ng Manggagawa (IBM) Labor Union on December 6, 1985, and the proclamation of private respondents as winners. The BLR, in resolving consolidated intra-union conflict cases, ordered a general election of officers within ten (10) working days. In compliance, a pre-election conference was held, setting the election date, candidacy filing deadline, and requiring San Miguel Corporation (SMC) to submit a list of union members. Subsequent conferences addressed voter inclusion/exclusion and the submission of names omitted from the list. Petitioners filed motions to disqualify private respondent Edilberto Galvez and his group due to alleged disloyalty for being officers/members of a rival union, and a motion to defer the election until the disloyalty charge was resolved. Private respondents opposed, arguing the motions were filed out of time and that the BLR lacked jurisdiction over the disloyalty issue, which they contended was an intra-union problem for the National Council. Despite these motions, the parties agreed to reschedule the election to December 6, 1985. The BLR denied the disqualification and deferment motions, stating the grounds were not in the union's constitution and by-laws, and that any disloyalty issue could be passed upon by the general membership in the election. The election proceeded, with private respondents winning. Petitioners filed a motion for reconsideration of the BLR's order and an election protest, reiterating their disloyalty claims. The BLR dismissed the protest and motion for reconsideration. A subsequent motion for reconsideration by petitioners was also denied, and private respondents were proclaimed duly elected officers. Procedural History: The case reached the Supreme Court via a petition for certiorari with a prayer for a writ of preliminary injunction, seeking to annul the BLR's December 5, 1985 Order and January 3, 1986 Resolution, and to hold another election if petitioners' proclamation was not feasible. The Petition: Petitioners prayed for the annulment of the BLR's orders and resolution, and for a new election if their proclamation as duly elected officers was not feasible.
Issue(s)
Whether the petition for certiorari is rendered moot and academic by the expiration of the terms of the elected union officers by operation of law. Whether the disqualification of private respondents due to alleged disloyalty would automatically result in the petitioners being declared winners in the disputed election.
Ruling
The petition is DISMISSED for being moot and academic. The Supreme Court did not grant the prayer for a writ of preliminary injunction. The proclamation of private respondents as duly elected officers of IBM union is affirmed.
Ratio Decidendi
On the issue of mootness due to expiration of term: The Supreme Court held that the petition for certiorari was rendered moot and academic by the operation of law. The Labor Code mandates that members of a labor organization shall elect their officers by secret ballot at intervals of not more than three (3) years. The election in question was held on December 6, 1985. Consequently, another election should have been held on December 6, 1988, and another three years thereafter on December 6, 1991. Since the terms of the private respondents, as elected officers, had expired by operation of law, the issues raised by the petitioners regarding the validity of the election and the disqualification of candidates became moot and academic. The Court reiterated its consistent ruling that where events or circumstances have taken place during the pendency of the case which would render the case moot and academic, the petition should be dismissed. It is pointless and unrealistic to insist on annulling an election of officers whose terms had already expired, as such a judgment would have no practical legal effect and could not be enforced. On the disqualification of private respondents: Although the Court dismissed the petition on the ground of mootness, it made a concluding remark regarding the petitioners' claim. The Court stated that even if the disqualification of private respondents could be justified, the petitioners could not automatically be declared winners in the disputed election. The mere fact that petitioner Villarosa obtained the second highest number of votes does not mean he would be considered the elected President if the private respondent were disqualified. This implies that the issue of disqualification, had it been resolved on the merits, would not necessarily have resulted in the petitioners' victory.
Main Doctrine
A petition for certiorari seeking to annul an election of union officers is rendered moot and academic by the expiration of the terms of the elected officers by operation of law, even if the issues raised were not resolved on the merits.