Pascual v. Caniogan Credit
REITERATIONFacts
The Antecedents: Petitioners Celso F. Pascual, Sr. and Serafin Terencio were appointed General Manager and Collection Manager, respectively, of Caniogan Credit and Development Cooperative (CCDC). Despite reaching retirement age, they continued in their positions. The CCDC Board of Directors subsequently passed resolutions terminating their services, setting specific end dates. However, Pascual and Terencio refused to vacate their positions, leading to a dispute over their continued occupancy of these roles. Procedural History: CCDC filed a Complaint for Injunction before the Regional Trial Court (RTC) of Malolos, Bulacan, seeking to enjoin Pascual and Terencio from performing their duties. The RTC issued a temporary restraining order. Pascual and Terencio filed a Motion to Dismiss, questioning the RTC's jurisdiction and arguing the case involved a labor dispute. The RTC initially referred the case to branches handling intra-corporate disputes, but another branch returned it, stating it was an intra-cooperative dispute. Ultimately, the RTC denied the Motion to Dismiss, finding it to be an intra-cooperative dispute, and granted motions to drop one plaintiff and admit an intervenor. Pascual and Terencio challenged this RTC Order via a Petition for Certiorari before the Court of Appeals (CA), which dismissed their petition as premature for failing to file a motion for reconsideration and for not exhausting intra-cooperative dispute resolution mechanisms. This dismissal was affirmed upon reconsideration. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's dismissal of their certiorari petition. They argue that the CA erred in dismissing their petition as premature, contending that the case is one of illegal dismissal falling under the exclusive jurisdiction of the Labor Arbiter or the National Labor Relations Commission, not the regular courts. They also raise the issue of whether prior recourse to mediation and conciliation mechanisms under Republic Acts No. 6938 and 6939 was necessary. The Supreme Court noted that the case had become moot and academic due to a subsequent judgment on the merits rendered by the RTC, which had become final and executory.
Issue(s)
Whether the Court of Appeals gravely erred in dismissing outright petitioners' Rule 65 Petition on the ground of prematurity. Whether the case is one of illegal dismissal of an employee subject to the exclusive jurisdiction of the Labor Arbiter or the National Labor Relations Commission, or an intra-cooperative dispute within the jurisdiction of the trial court.
Ruling
The Petition is DENIED. The case had become moot and academic with the finality of the judgment by default rendered by the RTC on July 20, 2006, which permanently enjoined petitioners from their positions and ordered them to pay attorney's fees and costs. Even on the merits, the petition must be denied.
Ratio Decidendi
On the issue of prematurity: The Court held that the general rule requires a motion for reconsideration before resorting to a special civil action for certiorari to give the court an opportunity to correct its errors. Petitioners' failure to file a motion for reconsideration justified the denial of their certiorari petition by the CA. The Court found no exceptional circumstances to justify this omission, noting that the trial court resolved the motions within a reasonable period of just over one month. The Court also disagreed with the CA's observation that prior recourse to modes of settlement under the Cooperative Code was necessary, as the records showed that mediation efforts before the Cooperative Development Authority had failed, resulting in a certificate of non-resolution. On the issue of jurisdiction: The Court affirmed the CA's ruling that the case involves an intra-cooperative dispute falling within the jurisdiction of the regular courts. The Court distinguished between a corporate officer and an employee, stating that an officer is appointed by the board of directors or stockholders and their removal is an intra-corporate matter. Petitioners, appointed by the Board of Directors and with salaries set by the Board, were officers, not employees. Their termination was therefore an intra-cooperative matter, not a labor dispute. The Court cited Article 121 of Republic Act No. 6938 and Section 8 of Republic Act No. 6939, which mandate the settlement of intra-cooperative disputes through conciliation or mediation, and if these fail, through a court of competent jurisdiction. Petitioners' participation in mediation before the Cooperative Development Authority further indicated their implied acceptance that the dispute was intra-cooperative.
Main Doctrine
An appeal of the outright dismissal of a petition for certiorari against an interlocutory order becomes moot and academic where, during its pendency, judgment on the merits has been rendered in the main case and has become final and executory. An intra-cooperative dispute between officers and the Board of Directors falls within the jurisdiction of regular courts, not of a Labor Arbiter.