G.R. No. 197889 , July 28, 2021
New World International Development (Phil.), Inc., Stephan Stoss and Geuel F. Auste, Petitioners, vs. New World Renaissance Hotel Labor Union, Respondent.

FACTS

Following a certification election on July 10, 2002, respondent New World Renaissance Hotel Labor Union was certified as the sole and exclusive bargaining agent of the hotel’s rank-and-file employees. On September 3, 2002, the union submitted a CBA proposal to petitioner hotel management but received no response. The union filed a complaint for unfair labor practice, alleging the hotel’s refusal to bargain. The hotel defended its refusal, citing a pending petition for cancellation of the union’s certification filed by some employees (BLR-A-C-73-8-15-03), which it considered a prejudicial question. The BLR dismissed this petition for cancellation on December 17, 2003, and the decision became final on January 16, 2004. The hotel’s subsequent petition for certiorari before the Court of Appeals (CA-G.R. SP No. 82428) was dismissed on November 17, 2004. Despite the finality of the BLR resolution, the hotel continued to refuse to bargain. The Labor Arbiter and the NLRC ruled in favor of the hotel, finding no unfair labor practice. The Court of Appeals reversed, ordering the parties to conduct collective bargaining negotiations and awarding attorney’s fees to the union. In their Supplemental Motion for Reconsideration before the Court of Appeals, petitioners raised a supervening event: on December 27, 2005, the union’s members passed resolutions dissolving the union and communicated this dissolution to the BLR and DOLE-NCR. The Court of Appeals denied the motion, ruling the issue was belatedly raised.

ISSUE

Whether the case has been rendered moot and academic due to the alleged dissolution of the respondent union by its members in December 2005.

RULING

Yes. The Supreme Court granted the petition and dismissed the case on the ground of mootness. The Court held that the supervening event—the dissolution of the respondent union as evidenced by resolutions passed by its members on December 27, 2005, and officially communicated to the BLR and DOLE-NCR—rendered the case moot and academic. A case becomes moot when there is no more actual controversy between the parties or no useful purpose can be served in passing upon the merits. The core issue was the hotel’s duty to bargain with the union. Since the union had allegedly ceased to exist, any ruling on the duty to bargain would be ineffectual. The union’s bare accusation that the dissolution was coerced did not negate the fact of dissolution. Consequently, the Court reversed and set aside the Decision and Resolution of the Court of Appeals and dismissed the amended complaint in NLRC-NCR Case No. 02-01243-05.