GR 70835; (April, 1990) (Digest)
G.R. No. 70835; April 20, 1990
ROGELIO P. CELI, MANUEL ABRAHAM, REDENTOR DE GOMA, ELEUTERIO NATERA, EMELITA SANCHEZ, petitioners, vs. HON. DIRECTOR CRESENCIANO B. TRAJANO, CRESTITUTO GONZALES, LEONARDO PALOMAR, HERMINIGILDO RAPANAN JR., CESAR YAP, MANOLO RUIZ, DOMINGO MONASTERIO, GABRIEL SIMS and JESUS SANTOS, respondents.
FACTS
The case originated from a dispute over the September 1983 election of officers for the Equitable Bank Employees Union (EBEU). The union’s Committee on Elections (COMELEC) set a cut-off date, declaring that only members as of August 5, 1983, were qualified to vote. During the election at the Head Office, petitioners, led by Rogelio P. Celi, protested the inclusion of 41 votes from members who joined after the cut-off date. Despite the protest, the Union COMELEC proceeded with the canvassing without segregating the challenged ballots.
Petitioners filed a protest with the Med-Arbiter, who, in an Order dated December 27, 1983, declared Celi the duly elected President but upheld the other election results. Dissatisfied, respondents appealed to the Bureau of Labor Relations (BLR). Director Cresenciano B. Trajano, in a decision dated March 5, 1985, set aside the Med-Arbiter’s Order and directed the holding of a new election. Petitioners then elevated the matter to the Supreme Court via certiorari, seeking to annul the BLR decision.
ISSUE
Whether the petition for certiorari assailing the BLR’s order for a new union election has been rendered moot and academic.
RULING
Yes, the petition is dismissed for being moot and academic. The Supreme Court noted that, based on the records, EBEU elections were constitutionally mandated to be held every three years. The disputed election took place in September 1983. Consequently, by the time the Court reviewed the case in 1990, the term of office for the positions contested in the 1983 election had long expired. In all probability, at least one subsequent election had already been conducted.
The legal logic is grounded in the principle that courts will not determine cases where no actual controversy exists or where the issues have ceased to be justiciable. A case becomes moot when it no longer presents a live, concrete dispute whose resolution will grant any practical relief or have any legal effect. Since the specific term of office from the 1983 election had ended, any judicial declaration on the validity of that election or the order for a new one would be ineffectual. The Court cannot issue a ruling that would have no practical impact on the rights of the parties regarding the expired term. Therefore, the petition was dismissed.