G.R. No. L-33367. January 31, 1978.
RODOLFO A. PAET, VICENTE BENEDICTO, ARTEMIO VILORIA, FELICISIMA CASTAÑEDA, NORA BUENVIAJE and GERVACIO NACALABAN, petitioners, vs. COURT OF FIRST INSTANCE OF RIZAL (BRANCH XVI), BONIFACIO G. PRUDENTE, LEOPOLDO FALCIS and ARTEMIO ASIA, respondents.

FACTS

Petitioners filed a petition for certiorari to annul an ex parte order from the Court of First Instance of Rizal (CFI). The CFI order granted a writ of preliminary injunction in favor of private respondents, lifting their suspension as officers and members of the National Directorate of the DBP Employees Union-NATU. This suspension stemmed from an internal union dispute, with petitioners leading the opposing faction. The core argument of the petition was jurisdictional: petitioners contended that the intramural labor dispute fell under the exclusive jurisdiction of the then-existing Court of Industrial Relations, not an ordinary court like the CFI.
The case progressed with the filing of memoranda. However, it remained pending during the transition period that saw the abolition of the Court of Industrial Relations and the enactment of the new Labor Code. Subsequently, on May 6, 1977, the Supreme Court issued a resolution requiring the parties to state whether the issue had become moot and academic. This inquiry was based on the undisputed fact that the tenure of the contested union offices had already terminated, and no restraining order had been issued to prevent the enforcement of the CFI’s injunction.

ISSUE

Whether the petition for certiorari challenging the CFI’s jurisdiction over an intramural labor union dispute has been rendered moot and academic.

RULING

Yes, the case is dismissed for being moot and academic. The legal logic for dismissal rests on the principle that courts will not adjudicate cases where no actual, substantial controversy exists between parties, or where the issues have been supervened by events rendering judicial resolution unnecessary. The Supreme Court’s resolution prompting the inquiry was grounded on two key factual developments. First, the term of office for the disputed union positions had expired. Second, in the absence of any restraining order from the Supreme Court, the CFI’s injunction remained enforceable, meaning the union’s internal affairs had presumably proceeded. Private respondents filed a manifestation confirming the issue was moot, noting that principal petitioners had retired or relocated. Petitioners, despite notice, raised no objection to this manifestation. Consequently, with the central conflict over union leadership extinguished by the passage of time and changed circumstances, any ruling on the jurisdictional question would be purely academic and without practical legal effect. The petition was therefore dismissed.