G.R. No. 193451, January 28, 2015
ANTONIO M. MAGTALAS, Petitioner, vs. ISIDORO A. ANTE, RAUL C. ADDATU, NICANOR B. PADILLA, JR., DANTE Y. CENIDO, and RHAMIR C. DALIOAN, Respondents.

FACTS

Petitioner Antonio M. Magtalas, the Certified Public Accountant (CPA) Review Director of the CPA Review Center of Philippine School of Business Administration-Manila (PSBA-Manila), was impleaded in his official capacity in a labor case. Respondents, professional reviewers engaged by PSBA-Manila on an hourly basis, were not given any review load for school year 2005-2006. They subsequently requested termination or retirement benefits, which PSBA-Manila, through Magtalas and President Jose F. Peralta, denied, asserting a professional-client rather than employer-employee relationship. Respondents then filed a complaint for constructive illegal dismissal and various monetary claims against PSBA-Manila, Peralta, and Magtalas before the Labor Arbitration Branch of the National Labor Relations Commission (NLRC).
The Labor Arbiter ruled in favor of respondents, declaring them regular employees and finding PSBA-Manila, Peralta, and Magtalas jointly liable for illegal dismissal, ordering payment of back wages, separation pay, and other benefits. Magtalas filed a separate appeal with the NLRC, posting a cash bond of ₱100,000.00 alongside a motion to reduce bond, citing incapacity to post the full amount (approximately ₱10,250,000.00). PSBA-Manila and Peralta separately posted a ₱50,000.00 cash bond with a similar motion. The NLRC dismissed the appeals for non-perfection, holding the posted bonds were not reasonable and did not interrupt the appeal period. The NLRC denied reconsideration.
Magtalas filed a Petition for Certiorari with the Court of Appeals (CA), which was consolidated with the separate petition of PSBA-Manila and Peralta. The CA affirmed the NLRC’s dismissal. Magtalas’s motion for reconsideration was denied.
During the pendency of Magtalas’s petition before the Supreme Court (docketed as G.R. No. 193451), and while related petitions by PSBA-Manila and Peralta (G.R. Nos. 193438 and 194184) were pending before the Second Division, respondents executed a “Release, Waiver, and Quitclaim” and an “Addendum” before the Labor Arbiter on March 23, 2011. These documents acknowledged full receipt of a negotiated settlement amount of ₱9,000,000.00 from PSBA-Manila, representing full and final settlement of all claims against the respondents (PSBA-Manila, its directors, officers, agents, and/or employees). PSBA-Manila and Peralta subsequently filed a Manifestation with Motion to Dismiss in G.R. Nos. 193438 and 194184, which the Court granted, considering those cases closed and terminated.

ISSUE

Whether the petition has been rendered moot and academic by the execution of the Release, Waiver, and Quitclaim and its Addendum by the respondents, which constituted a full and final settlement of all their claims against the respondents, including the petitioner.

RULING

Yes, the petition is denied on the ground of mootness. The Supreme Court held that the execution of the Release, Waiver, and Quitclaim and its Addendum by the respondents on March 23, 2011, wherein they acknowledged full receipt of ₱9,000,000.00 from PSBA-Manila and declared it as full and final settlement of all claims for remuneration, wages, and benefits of whatever nature from the respondents (including Philippine School of Business Administration, Inc. – Quezon City, its directors, officers, agents, and/or employees), rendered the instant petition moot and academic. The Court noted that none of the respondents assailed the validity of these documents in this petition or in the consolidated cases (G.R. Nos. 193438 and 194184), nor did they oppose the Motion to Dismiss filed in those related cases, which the Court had already granted. Consequently, no justiciable controversy remained for the Court to resolve.