Ocampo v. Court of Appeals
REITERATIONFacts
The Antecedents: The Philippine Airlines Employees Association (PALEA) conducted a general election for its officers from February 17 to 24, 2000. Following the election, a dispute arose concerning the canvassing of approximately 500 segregated ballots and ballots from three questioned ballot boxes. This led to a petition filed with the Department of Labor and Employment-National Capital Region (DOLE-NCR) to assume jurisdiction and complete the canvassing. Procedural History: The DOLE-NCR initially dismissed a petition filed by Nida Villagracia due to prematurity. Subsequently, another petition was filed by Edgardo Oredina, seeking to declare a failure of election. The DOLE-NCR granted this petition, nullifying the election results and ordering a new election under DOLE supervision. The Bureau of Labor Relations (BLR) denied the appeal filed by the proclaimed winners, including the petitioners. Jose Peñas III, one of the proclaimed winners, filed a petition for certiorari with the Court of Appeals (CA), which affirmed the BLR's resolution. Peñas did not pursue further action. The Petition: The petitioners, who were co-respondents in the lower proceedings but not parties to the certiorari case before the CA, filed this petition for review on certiorari under Rule 45 of the Rules of Court. They assert the same arguments previously raised by Peñas, contending that the DOLE-NCR and BLR lacked jurisdiction due to the premature filing of the petition by Oredina's group. The Supreme Court, however, denied the petition, ruling that the petitioners were not proper parties to appeal the CA decision as they had failed to join Peñas in his certiorari petition before the CA or file their own within the reglementary period, thus allowing the BLR resolution to become final as against them.
Issue(s)
Whether petitioners, who were not parties to the case before the Court of Appeals but were co-respondents in the original action before the DOLE-NCR and BLR, are proper parties to file a petition for review on certiorari with the Supreme Court. Whether the DOLE-NCR and BLR had jurisdiction over the controversy due to prematurity and failure to exhaust administrative remedies, and whether the intra-union controversy had become moot and academic.
Ruling
The petition is denied for lack of merit. The Supreme Court ruled that the petitioners are not proper parties to file the petition for review on certiorari. The CA decision had become final and binding as against them due to their failure to file a petition for certiorari with the CA within the reglementary period after the BLR denied their motion for reconsideration. Furthermore, the intra-union controversy has been rendered moot and academic, and the petitioners are deemed to have abandoned their claim by actively participating in the formulation of new election guidelines and by petitioner Ocampo filing her certificate of candidacy for the new election.
Ratio Decidendi
On the issue of proper parties: The Court reiterated the basic rule that a party who fails to question an adverse judgment or decision by not filing the proper remedy within the prescribed period loses the right to do so, and the judgment becomes final and binding as to them. In this case, the petitioners, despite being aware of the BLR Resolution denying their motion for reconsideration, did not join Jose T. Peñas III in his petition for certiorari before the Court of Appeals. This failure to act within the reglementary period constituted a serious procedural lapse, leading to the finality of the BLR Resolutions against them. Consequently, they lacked the legal personality to pursue the appeal before the Supreme Court, as a petition for review on certiorari under Rule 45 is a continuation of the original suit, and they were not parties to the original suit before the CA. The Court emphasized that procedural rules may be relaxed only on exceptional grounds or under extraordinary circumstances, which were not present in this case. The Court also noted that the petitioners' inaction allowed the judgment to become final and executory, and they could not subsequently seek to assail it through iniquitous ways. The finality of a decision is a jurisdictional event that cannot depend on the convenience of the parties. On the issue of jurisdiction and prematurity: While the Court dismissed the petition on procedural grounds, it also noted that the intra-union controversy had become moot and academic because the five-year term of office being contested had already expired. Furthermore, the petitioners' active participation in the formulation of new election guidelines and the filing of a certificate of candidacy by one of them for the new election demonstrated their acquiescence to the BLR's order for a new election, estopping them from further pursuing their petition. This indicates that the underlying dispute regarding the validity of the initial election had been superseded by subsequent events and actions of the parties.
Main Doctrine
A party who fails to question an adverse judgment or decision by not filing the proper remedy within the period prescribed by law loses the right to do so, and the judgment or decision, as to him, becomes final and binding. Failure to join a co-party in a certiorari petition before the appellate court constitutes a serious procedural lapse that tolls the finality of the resolutions against them.