GR 108033; (April, 1997) (Digest)
G.R. No. 108033 . April 14, 1997.
TEOFISTO C. GANCHO-ON, petitioner, vs. THE HONORABLE SECRETARY OF LABOR AND EMPLOYMENT AND LAKAS NG NAGKAKAISANG MANGGAGAWA-PAFLU, respondents.
FACTS
Respondent Union filed a petition for certification election to represent the truck drivers of Eros Repair Shop. Petitioner Teofisto C. Gancho-on, the shop owner, moved to dismiss the petition, arguing no employer-employee relationship existed. He claimed the drivers were employees of individual truck owners, not his automotive repair shop, and presented vehicle certificates of registration to support this. The Union opposed, asserting that Gancho-on’s wife managed a trucking and hauling business under the same name, “Eros Repair Shop,” and exercised control over the drivers. It submitted her affidavit and letters to the DOLE discussing driver discipline and absences.
The Med-Arbiter found that the right to control the drivers was exercised by petitioner’s wife, the entities were not distinct, and most trucks were owned by the spouses. The petition for certification election was thus granted. Petitioner appealed to the Secretary of Labor, which denied the appeal, upholding the finding of an employer-employee relationship based on the admissions and actions of petitioner’s wife. The certification election proceeded on January 11, 1993.
ISSUE
Whether the Supreme Court should resolve the issue of the existence of an employer-employee relationship between petitioner and the truck drivers.
RULING
No. The petition is dismissed for being moot and academic. The legal logic is grounded in the principle that courts will not adjudicate moot cases where no substantial rights or actual interests remain for resolution. The certification election, which was the sole proceeding from which this case originated, has already been conducted. The Union lost, as all voting drivers favored “no union.”
Consequently, the factual findings on employer-employee relationship made by the Med-Arbiter and the Secretary of Labor have been rendered irrelevant by this electoral result. The issue was ancillary to the certification election proceeding; with that proceeding concluded by the Union’s defeat, the case has lost its raison d’être. A judicial declaration on the moot issue would serve no practical purpose or provide any actual substantial relief to the petitioner. The Court therefore declines jurisdiction.