G.R. No. L-32850. May 30, 1978.
ROGELIO LAFIGUERA and THE DON BOSCO TECHNICAL INSTITUTE EMPLOYEES ORGANIZATION, petitioners, vs. THE HONORABLE V. M. RUIZ, Presiding Judge of the Court of First Instance of Rizal, Branch XV, Makati, Rizal and MARIA FRANCISCA GERONIMO, MARCELA MAGSINO, MARITA SANTIAGO, and ILUMINADA SANTOS, respondents.

FACTS

Petitioners Rogelio Lafiguera and the Don Bosco Technical Institute Employees Organization filed this certiorari and prohibition proceeding. They assailed the actuation of respondent Judge V. M. Ruiz of the Court of First Instance of Rizal, Branch XV, in assuming jurisdiction over a complaint for injunction intended to prohibit acts of picketing in connection with a strike. The complaint was filed by private respondents, who were faculty members. Respondent Judge immediately issued a restraining order without a hearing, ordering the labor organization to refrain from delivering allegedly defamatory speeches via a radio system, displaying libelous placards, and committing acts intended to disturb classes.
Petitioners filed an urgent motion to dismiss the complaint and to reconsider the restraining order. They stressed that respondent Judge lacked jurisdiction over the subject matter because the controversy involved unfair labor practices and claims for overtime and minimum wages that had been filed weeks earlier before the Court of Industrial Relations (CIR). They noted a pending notice of strike before the Department of Labor and a pending unfair labor practice charge in the CIR. Respondent Judge, however, maintained his power to act and threatened contempt action against petitioners after the lapse of five days from the restraining order’s issuance.

ISSUE

Whether the Court of First Instance had jurisdiction to issue an injunction in a labor dispute involving picketing, given the pendency of related labor cases before the Court of Industrial Relations.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic for this dismissal is rooted in the principle that courts will not determine questions that no longer present a justiciable controversy due to subsequent events. The Court noted that the petition was argued orally in 1970, and since then, no further pleadings were submitted nor any inquiry made about the case’s status. In 1977, the Court required the parties to inform it of any developments, considering that labor disputes often become settled or are disposed of by labor tribunals over time.
Private respondents filed a responsive pleading stating that the case had become moot and academic due to subsequent developments and the general orders issued after the proclamation of martial law, and they moved for dismissal. Counsel for petitioners, duly served with this resolution, took no action. The Court interpreted this inaction as an implicit acknowledgment of the academic nature of the controversy. Consequently, without reaching the substantive jurisdictional issue between the Court of First Instance and the Court of Industrial Relations, the Court dismissed the petition. No costs were awarded.