Cariño v. Ofilada
REITERATIONFacts
The Antecedents: Respondents, public school teachers, participated in a "mass action" on September 21, 1990, in solidarity with a strike in the National Capital Region. For failing to comply with return-to-work orders, the Regional Director of the Department of Education, Culture and Sports (DECS) initiated administrative complaints. Separate decisions were rendered: one dismissing Priscilla Ramos and twenty-seven others, and another suspending Benilda Sarmiento and eleven others for one year. These decisions were confirmed by the Secretary of DECS. Procedural History: Following the dismissal decisions, the affected teachers filed a petition for mandamus with the Regional Trial Court (RTC) seeking reconsideration, alleging lack of hearing and evidence. The RTC initially ordered their reinstatement. This Court, in a prior petition (G.R. No. 100206), remanded the case to the RTC for further proceedings, allowing for reinstatement pending determination and encouraging DECS to re-examine its decisions. Consequently, DECS recalled its dismissal decision and reinstated the teachers, also preparing a payroll for backwages. Subsequently, a group of teachers, who were not original petitioners, filed a motion to intervene in the RTC case, seeking similar relief. The RTC allowed this intervention and issued a writ of preliminary mandatory injunction for the reinstatement and back salaries of the intervenors. The Petition: Petitioners, the Secretary of DECS and the Regional Director, filed this special civil action for certiorari, prohibition, and mandamus under Rule 65 of the Rules of Court. They contend that the RTC gravely abused its discretion and acted without or in excess of jurisdiction by allowing the intervention and by issuing the preliminary mandatory injunction. Petitioners argue that the RTC should have dismissed the case after the original respondents were reinstated and paid backwages, rendering the mandamus petition moot. Furthermore, they assert that the intervenors lacked the requisite legal interest for intervention and that the injunction was improperly granted without proper notice and hearing.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion and acted without or in excess of jurisdiction in allowing the petition for intervention. Whether the respondent Judge committed grave abuse of discretion and acted without or in excess of jurisdiction in not dismissing the case after the reinstatement and payment of backwages of the original respondent teachers.
Ruling
The Supreme Court GRANTED the petition, SET ASIDE the challenged order of the respondent Judge dated October 29, 1991, and directed the respondent Judge to DISMISS Civil Case No. 210-M-91. The Court further directed the petitioners to reinstate the Private Respondents-Intervenors, taking into account the observations made in the decision.
Ratio Decidendi
On the issue of allowing intervention: The Court ruled that intervention was improper. Intervention requires a legal interest in the matter in litigation, which must be actual, material, direct, and immediate, not merely contingent or expectant. The interest of the Private Respondents-Intervenors was personal and could be fully protected in a separate suit. Furthermore, intervention must be sought before or during the trial, which in this context refers to the period for introducing evidence. Since the original petitioners' cause of action was extinguished by the recall of the decision, there was nothing left to aid or fight for, rendering the intervention moot. The RTC's act of allowing intervention and issuing a preliminary mandatory injunction without proper notice and hearing, especially after granting petitioners time to file an opposition, constituted grave abuse of discretion. On the issue of not dismissing the case: The Supreme Court held that the RTC committed grave abuse of discretion by continuing to hear Civil Case No. 210-M-91 after the administrative decision that was the subject of the mandamus petition had been recalled by DECS Regional Director Reyes on September 6, 1991. This recall, prompted by the Supreme Court's resolution in G.R. No. 100206, rendered the original petition for mandamus moot and academic, as the purpose of seeking recall or reconsideration of the decision was fulfilled. The RTC itself acknowledged that the case should be dismissed upon payment of backwages and reinstatement, yet it proceeded to allow intervention and issue an injunction, thereby acting without a valid basis.
Main Doctrine
The Supreme Court set aside the order of the Regional Trial Court allowing intervention and issuing a preliminary mandatory injunction, holding that the intervention was improper as the intervenors' cause of action was extinguished by the recall of the administrative decision, and that the main case had become moot and academic, thus warranting dismissal. The Court also directed the reinstatement of the intervenors, considering that their suspension periods had lapsed.