G.R. No. L-17650 June 22, 1965
KAPISANAN NG MGA MANGGAGAWA SA MANILA RAILROAD COMPANY, petitioner, vs. HON. JESUS DE VEYRA, of the Court of First Instance of Baguio City, MANILA RAILROAD COMPANY and BENGUET AUTO LINES EMPLOYEES UNION, respondents.

FACTS

On September 22, 1959, Benguet Auto Line Employees Union (BALEU) filed a petition for certification election before the Court of Industrial Relations (CIR), docketed as Case No. 15-MC-PANG. Kapisanan Ng Mga Manggagawa sa Manila Railroad Company (KAPISANAN) intervened. In an order dated April 29, 1960, the CIR authorized a certification election to be held after the expiration of the existing collective bargaining agreement (CBA) between KAPISANAN and Manila Railroad Company (MRRCO) on November 5, 1960. The parties agreed that until the election, no union could negotiate a new CBA, and the provisions of the existing CBA, including its union shop clause, would be followed. Pursuant to this clause, KAPISANAN served notice to MRRCO regarding employees not complying. On June 3, 1960, KAPISANAN filed an unfair labor practice (ULP) charge against MRRCO and BALEU concerning the union security clause. While this ULP charge was under investigation, BALEU filed a petition for injunction on July 11, 1960, before the Court of First Instance (CFI) of Baguio, docketed as Civil Case No. 974, seeking to enjoin MRRCO from enforcing the union security clause, alleging it was contrary to law and burdensome. KAPISANAN was not initially made a party. On July 16, 1960, respondent Judge Jesus de Veyra issued a writ of preliminary injunction restraining MRRCO from dismissing non-member employees. KAPISANAN moved to intervene, which was granted, and then moved to dismiss the injunction case on August 20, 1960, on the ground that the CFI had no jurisdiction because a ULP complaint (formally filed on July 27, 1960) was pending before the CIR involving related matters. The respondent Judge denied the motion to dismiss and a subsequent motion for reconsideration, reasoning that the formal ULP complaint was filed after the injunction case. KAPISANAN then filed the instant Petition for Certiorari, alleging the respondent Judge acted without or in excess of jurisdiction or with grave abuse of discretion.

ISSUE

Whether the Court of First Instance of Baguio City had jurisdiction to take cognizance of the petition for injunction filed by BALEU, considering that a charge of unfair labor practice involving the same subject matter (the union security clause) had been filed before the Court of Industrial Relations prior to the filing of the injunction case.

RULING

The Supreme Court dismissed the petition as moot. The Court found that during the pendency of the case, the collective bargaining agreement between KAPISANAN and MRRCO had expired on November 5, 1960, and a certification election was conducted on January 18 and 19, 1961, wherein BALEU was certified as the sole and exclusive bargaining representative for the employees. Furthermore, the unfair labor practice case (Case No. 2449-ULP) before the CIR had already been dismissed on September 26, 1961. Since the provisions of the CBA questioned in the injunction case were no longer enforceable and the ULP case which was the basis for challenging the CFI’s jurisdiction had been dismissed, any decision on the jurisdictional issue would be purely academic. The writ of preliminary injunction issued by the Supreme Court was ordered dissolved.