G.R. No. L-18927 September 30, 1963
Government Service Insurance System Employees Association (CUGCO-KMP), et al., petitioners, vs. Hon. Gregorio T. Lantin, et al., respondents.

FACTS

A labor dispute arose between several unions of the Government Service Insurance System (GSIS) and the GSIS itself regarding the implementation of a collective bargaining agreement on salary scales. This dispute was certified to the Court of Industrial Relations. During the ensuing strike, union leaders attempted to negotiate with GSIS Chairman Gregorio S. Licaros, who refused. The unions then filed an unfair labor practice complaint against him. Concurrently, union members established pickets around GSIS premises. Chairman Licaros, who also chaired the Development Bank of the Philippines (DBP), allowed GSIS officials to operate from DBP premises to maintain functions. The unions subsequently extended their peaceful picketing to the DBP premises.
The DBP filed an action in the Court of First Instance of Manila to prohibit the picketing of its premises and sought a preliminary injunction. Presiding Judge Gregorio T. Lantin issued the writ ex parte upon the DBP’s filing of a cash bond, without a prior hearing. Manila police enforced the order, dispersing picketers and making arrests even before the unions were formally served the writ. The unions filed this certiorari petition, alleging Judge Lantin acted without jurisdiction or with grave abuse of discretion by violating Republic Act 875 (the Industrial Peace Act).

ISSUE

Whether the petition for certiorari assailing the ex parte issuance of a preliminary injunction against picketing has been rendered moot and academic.

RULING

Yes, the petition is moot and academic. The Supreme Court dismissed the petition. 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 live. Subsequent events had supervened: the underlying labor dispute between the GSIS and the unions was amicably settled, resulting in the employees returning to work. Furthermore, the writ of preliminary injunction issued by the respondent court had become moot with the cancellation of the cash bond filed by the DBP. Since the primary cause of action—the labor dispute—and the specific injunctive relief being challenged had both been resolved, any judicial declaration on the propriety of the ex parte injunction would be without practical legal effect. The Court, therefore, refrained from making an academic ruling on the alleged violation of Republic Act 875, as no justiciable controversy remained for adjudication.