G.R. No. 80141 July 5, 1989
SAN MIGUEL CORPORATION EMPLOYEES UNION PTGWO, et al., petitioners, vs. HON. PURA FERRER CALLEJA, et al., respondents.

FACTS

The controversy stemmed from a petition filed by the San Miguel Corporation Employees Union itself on December 2, 1984, seeking an election of its officers, as the last election was in December 1981. The scheduled December 1984 election was restrained, but one faction proceeded anyway, leading to protracted litigation. The Bureau of Labor Relations (BLR) ultimately ordered a new election. Petitioner union officers, led by Raymundo Hipolito, Jr., engaged in successive legal maneuvers that delayed the election for years, including a petition to this Court to add “PTGWO” to the union’s name, which was granted. After the case was remanded and a collective bargaining agreement was concluded, the Med-Arbiter set the election for September 15, 1987. Petitioners moved for reconsideration but subsequently filed a manifestation agreeing to participate if the date was moved. The Med-Arbiter granted the rescheduling and deemed the motion for reconsideration moot. The Representation Officer then set the election for October 5, 1987. Petitioners participated, with Hipolito losing the presidency, but then filed this certiorari petition and an election protest. The Med-Arbiter dismissed the protest and proclaimed the winners on November 6, 1987.

ISSUE

Whether public respondents committed grave abuse of discretion in ordering and supervising the union election of October 5, 1987, and whether they should be held in contempt.

RULING

The Supreme Court dismissed the petition. On the claim of grave abuse of discretion, the Court ruled petitioners were estopped from challenging the sufficiency of the original election petition, as they themselves had filed it, thereby affirming its compliance with legal requirements. Their due process claim also failed, as records showed they were given ample opportunity to be heard through motions and conferences; the denial of their pleas did not equate to a denial of due process. Regarding contempt, the Court noted that the temporary restraining order it issued on December 9, 1987, sought to enjoin the proclamation of winners. However, the proclamation had already occurred on November 11, 1987, pursuant to the Med-Arbiter’s November 6 order resolving the election protest. Since the act sought to be restrained was already a fait accompli before the restraining order was issued, respondents could not be held in contempt for violating it. The petition, having been rendered moot by the consummated election and proclamation, and lacking merit, was dismissed.