G.R. No. L-19785 January 30, 1967
MERALCO WORKERS UNION, petitioner, vs. The Honorable Judge NICASIO YATCO and MANILA ELECTRIC COMPANY, respondents.

FACTS

The Manila Electric Company (Company) filed a complaint against the Meralco Workers Union (Union) in the Court of First Instance of Quezon City, praying for a writ of preliminary injunction. The Company sought to restrain the Union from obstructing, blocking, coercing, intimidating, or preventing company officials and non-striking employees from entering or leaving the company’s main office, power plants, and other stations. The Union opposed the injunction, arguing the court lacked jurisdiction as the matter involved a labor dispute. After a hearing, respondent Judge Nicasio Yatco granted the writ on May 18, 1962. The court’s order was based on established facts from the hearing, including: the Union declared a strike on May 3, 1962; picketers blocked access to company premises, coercing and intimidating non-striking employees; at the Rockwell station, employees were detained and food supply was blocked, with attempts to airdrop food met with rockets; at the Blaisdell station, access was blocked and attempts to supply food by tugboat were intercepted; in Manila, the picket line prevented entry of non-striking employees and customers; an incident in Quezon City involved a union member assaulting a non-striking employee with a shotgun; and a transmission tower was sawed off. The Union moved for reconsideration but subsequently filed this petition for certiorari with preliminary injunction in the Supreme Court and withdrew its motion for reconsideration in the lower court. On May 30, 1962, the Union and Company entered into a “Return to Work Agreement” in the Bureau of Labor Relations, settling the labor dispute, ending the strike and picketing, and reinstating employees under a no-strike, no-lockout stipulation. The Company then moved to dismiss the petition as moot.

ISSUE

Whether the petition for certiorari should be dismissed as moot and academic due to the settlement of the labor dispute between the parties.

RULING

Yes, the petition is dismissed. The Supreme Court ruled that the issues had become moot and academic. The acts enjoined by the writ of preliminary injunction issued by the respondent Judge no longer existed due to the “Return to Work Agreement” that settled the labor dispute. The Court adheres to the settled rule that it will not determine moot questions or abstract propositions, nor express an opinion in a case where no practical relief can be granted. The Union’s objection, based on a claim for damages from the allegedly improper issuance of the injunction, was without merit. The Court noted that the preliminary injunction was not against the strike or picketing per se, but against specific acts of violence and intimidation which were unjustified and unlawful. Therefore, such an order could not be a valid basis for a damage claim. Furthermore, the amicable settlement of the main dispute without reservation for damages warranted a definite termination of the litigation to preserve industrial peace. The petition was dismissed without pronouncement as to costs.