GR L 27382; (March, 1975) (Digest)
G.R. No. L-27382 March 25, 1975
ASSOCIATED LABOR UNION, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, THE SECRETARY OF LABOR, NATIONAL SUGAR WORKERS’ UNION-PAFLU, and CENTRAL AZUCARERA DE LA CARLOTA, respondents.
FACTS
The petitioner, Associated Labor Union, sought to restrain the holding of a certification election among the rank-and-file employees of Central Azucarera de la Carlota, as ordered by the respondent Court of Industrial Relations. The petitioner’s primary objection was the alleged exclusion of nearly eighty employees, presumed to be its members, from the list of eligible voters. Despite a motion for reconsideration, the Court en banc upheld the order for the election.
Subsequently, the respondent National Sugar Workers’ Union-PAFLU, in its answer, revealed that the certification election had already been conducted, but the canvassing of ballots was enjoined by the industrial court. It further alleged that the petitioner’s suit was merely a dilatory tactic. This Court, in a resolution dated May 19, 1967, ordered the respondent court to proceed with the counting of the ballots and to report the results.
ISSUE
Whether the petition for certiorari and prohibition to restrain the certification election has been rendered moot and academic.
RULING
Yes, the petition is dismissed for being moot and academic. The legal logic is grounded in the principle that courts will not determine a case where no actual controversy exists or where the issues have ceased to be justiciable. The factual developments subsequent to the filing of the petition clearly demonstrate the absence of a live dispute.
First, the very act sought to be prevented—the holding of the certification election—had already taken place. The Supreme Court’s subsequent order to canvass the ballots effectively recognized this supervening event. Second, there was a significant lapse of time without any action from the parties, particularly the petitioner, which failed to file its promised memorandum. This inaction implies an abandonment of its cause. Third, the abolition of the respondent Court of Industrial Relations, whose order was being challenged, further removed any practical legal effect a ruling could have. The Court concluded that the petitioner, for its own reasons, had decided to let the matter rest, and no tangible relief could be granted. Therefore, resolving the petition on its merits would be an exercise in futility.