G.R. No. L-33534. June 20, 1977.
DOMINADOR DE LOS REYES, petitioner, vs. BENGUET CONSOLIDATED, INC., BCI EMPLOYEES AND WORKERS UNION-PAFLU, ELISEO P. FLORA, and THE COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

Petitioner Dominador de los Reyes was expelled from the respondent BCI Employees and Workers Union-PAFLU, leading to the termination of his employment by Benguet Consolidated, Inc. He subsequently filed an unfair labor practice case before the respondent Court of Industrial Relations (CIR) against both the company and the union. During the pendency of this suit, the union held its election of officers in 1971. The CIR did not permit de los Reyes to run as a candidate in this election, precisely because his unfair labor practice case, which challenged the validity of his expulsion and termination, was still unresolved. De los Reyes then filed this certiorari proceeding, alleging that the CIR committed grave abuse of discretion in disqualifying him from the union election.

ISSUE

Whether the Court of Industrial Relations gravely abused its discretion in disqualifying petitioner from running in the respondent union’s 1971 election due to the pendency of his unfair labor practice case.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic for dismissal rests on the principle that courts will not determine questions that no longer present a justiciable controversy due to subsequent events. The Court, prior to its decision, required the parties to manifest whether the case had been rendered moot. The respondents submitted manifestations establishing supervening events: de los Reyes had lost his unfair labor practice case in the CIR, a decision he did not appeal, thereby finalizing his valid expulsion from the union. Furthermore, the union had conducted two subsequent elections after 1971, which de los Reyes never questioned. Most significantly, de los Reyes had since become a District Regional Director for a rival union, the National Mines and Allied Workers Union (NAMAWU-MIF). These facts demonstrated that the specific issue of his eligibility in the 1971 election had been overtaken by circumstances, stripping it of practical legal significance. Petitioner’s failure to submit any comment or memorandum, despite opportunities granted by the Court, further evidenced a lack of continuing interest in the case. Consequently, with no live controversy remaining for judicial resolution, the petition was dismissed.