GR 109012; (July, 1994) (Digest)
March 12, 2026AM MTJ 10 1760; (November, 2015) (Digest)
March 12, 2026G.R. No. L-3746; August 30, 1951
National Airports Corporation, petitioner, vs. V. Jimenez Yanson as Associate Judge of the Court of Industrial Relations and National Airports Corporation Employees and Laborers Association, respondents.
FACTS
The National Airports Corporation Employees and Laborers Association, a registered labor union, submitted a petition to the National Airports Corporation (NAC) making several demands, including recognition as the sole collective bargaining agency, intervention in personnel and budgetary matters, standardization of salaries, a minimum wage, night shift differentials, and a closed shop contract. As its demands were unheeded, the union filed a petition with the Court of Industrial Relations (CIR) to compel the NAC to grant them. The NAC moved to quash the petition, arguing that as a government agency exercising governmental functions, it could not be sued without the state’s consent; that its funding relied on congressional appropriations, making employment contingent; and that its functions were governmental, placing the dispute outside the CIR’s jurisdiction under Commonwealth Act No. 103. The CIR denied the motion to quash and a subsequent motion for reconsideration. The NAC then filed this petition to enjoin the CIR from hearing the case, and a preliminary injunction was issued.
ISSUE
Whether the Court of Industrial Relations had jurisdiction to hear and decide the labor dispute petition filed by the union against the National Airports Corporation.
RULING
The petition was dismissed. The controversy had become moot. Republic Act No. 224, which created the National Airports Corporation, had been repealed, and the corporation was abolished by Executive Order No. 365 dated November 10, 1950. Its functions, powers, and duties were taken over by the Civil Aeronautics Administration (CAA). Even if the Supreme Court were to rule that the CIR had jurisdiction and the CIR decided in favor of the union, any such decision would be unenforceable. This is because the CAA, which succeeded the NAC, is an office or agency of the Government of the Republic, and the state may not be sued without its consent.