G.R. No. L-27469, December 19, 1980
NATIONAL SUGAR WORKERS UNION-PAFLU, ET AL. vs. HON. ARSENIO I. MARTINEZ, ET AL.

FACTS

The Associated Labor Union (ALU) filed a petition for a certification election among the workers of Central Azucarera De La Carlota. The Court of Industrial Relations (CIR), through Presiding Judge Arsenio I. Martinez, granted the petition, ordering an election between ALU and the National Sugar Workers Union-PAFLU (NASWU-PAFLU). ALU filed a motion for reconsideration and a motion to suspend the election. The CIR en banc initially suspended the election but later, on March 14, 1967, denied ALU’s motion and lifted the suspension, allowing the election to proceed. The Department of Labor scheduled the election for April 11, 1967.
On April 9, 1967, ALU sought an injunction from the CIR en banc to suspend the election, citing its pending petition for certiorari before the Supreme Court challenging the CIR’s orders. Despite the motion being addressed to the court en banc, Judge Martinez, acting alone, issued an order on April 11, 1967. This order permitted the election to be held but directed that the canvassing of votes be deferred and the ballots sealed until the Supreme Court decided ALU’s certiorari petition. Consequently, the Department of Labor supervisors suspended the vote count.

ISSUE

Whether or not respondent Presiding Judge committed grave abuse of discretion in issuing the order dated April 11, 1967, which deferred the canvassing of the certification election results.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal issue was rendered inconsequential by a supervening event. Prior to this case, in G.R. No. L-27382 (a related case involving the same certification election), the Supreme Court had already resolved the matter. In a resolution dated May 19, 1967, the Court ordered the CIR to proceed with the counting of the ballots cast in the very same election and to report the results. Subsequently, G.R. No. L-27382 itself was dismissed as moot, given the passage of time, the inaction of the parties, and the abolition of the CIR.
Therefore, the specific question of whether Judge Martinez gravely abused his discretion in issuing the April 11, 1967 order lost its practical legal significance. The relief sought—to compel the canvassing of votes—had already been mandated by the Supreme Court’s earlier directive in the related case. The Court applied the same rationale for dismissal, noting the election had long been held and the institutional context (the CIR) no longer existed, leaving no live controversy for judicial resolution.