G.R. Nos. 148839-40; November 2, 2006
NAGKAHIUSANG MAMUMUO SA PICOP RESOURCES, INC. SOUTHERN PHILIPPINES FEDERATION OF LABOR (NAMAPRI SPFL), ARTEMIO Q. AVILA, ET AL., Petitioners, vs. THE HON. COURT OF APPEALS (Fifth Division) and PICOP RESOURCES, INC., Respondents.

FACTS

Petitioner NAMAPRI-SPFL is the recognized union of rank-and-file employees at respondent PICOP Resources, Inc.’s paper and plywood plants. In 1997, PICOP declared a temporary shutdown, prompting the union to file a notice of strike and later stage a strike in January 1998, including picketing and barricades. The Secretary of Labor assumed jurisdiction over the dispute, ordering the striking workers to return to work and PICOP to accept them back. Subsequently, PICOP announced the permanent closure of its plywood plant, leading to another strike in March 1998 and the eventual dismissal of all workers.
The Labor Secretary issued an Order on September 9, 1999, which, among other things, declared the permanent retrenchment at the plywood plant valid but directed all striking workers (except those already validly retrenched) to return to work pending resolution of the illegal strike issue. Both parties filed motions for reconsideration, which were denied. The Secretary then issued a Writ of Execution to enforce the reinstatement order. PICOP challenged this writ before the Court of Appeals, which issued a Resolution enjoining its enforcement and later granted a writ of preliminary injunction against it.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in enjoining the enforcement of the Labor Secretary’s Writ of Execution ordering the reinstatement of the striking workers.

RULING

The Supreme Court denied the petition, ruling it had become moot and academic. The legal logic is anchored on the principle that courts will not determine questions that no longer present a justiciable controversy. The Court noted that a separate but related Decision by the Court of Appeals, dated March 22, 2001, had already annulled the very Labor Secretary’s Order (dated July 5, 2000) which was the foundation for the contested Writ of Execution. This March 22, 2001 CA Decision was subsequently affirmed by the Supreme Court in a related case on September 12, 2001.
Since the underlying Order directing reinstatement had been invalidated by a final and executory judgment, the Writ of Execution issued to enforce that void order lost its legal basis. Consequently, the propriety of the CA’s actions in enjoining that writ became a moot question. There was no longer any live controversy for the Court to adjudicate, as the relief sought by petitionersthe enforcement of the reinstatement ordercould no longer be granted given the annulment of its source. The Court therefore refrained from making a determination on the alleged grave abuse of discretion.