G.R. No. L-28903 August 22, 1968
MARINDUQUE MINING INDUSTRIAL CORPORATION, plaintiff-appellee, vs. SANTIAGO YAP, ET AL., defendants-appellants, PHILIPPINE ASSOCIATION of FREE LABOR UNIONS (PAFLU), JESUS RIPULAN, ET AL., defendants-appellees.

FACTS

Pursuant to a collective bargaining agreement effective May 16, 1964, between Marinduque Mining & Industrial Corporation (Marinduque) and two unions—PAFLU and the National Mines and Allied Workers Union (NAMAWU-PAFLU), Sipalay Chapter—a check-off privilege was granted for union dues. The agreement stipulated that one-half of the dues collected by the company via check-off would be paid to the local Sipalay Chapter and the other half to PAFLU Manila. A dispute arose between the local chapter and PAFLU Manila regarding the implementation of this check-off provision. On February 11, 1965, local officers of NAMAWU resolved to withhold the portion destined for PAFLU Manila. On May 4, 1965, PAFLU requested Marinduque to withhold payment of all check-off dues until competent authorities decided the entitlement. Consequently, Marinduque filed a petition for interpleader in the Court of First Instance of Negros Occidental against the two unions and their officers, including Prudencio Jalandoni and Santiago Yap, praying that the unions interplead their conflicting claims and that the company be allowed to deposit the withheld dues in court. Defendants-appellants Santiago Yap, et al., were declared in default on January 17, 1966, and appealed from that order. While the case was pending appeal, a certification election was conducted on June 9, 1967, at Marinduque in Sipalay, between a new union, Lakas ng Manggagawang Makabayan (ALU)—represented by appellants Prudencio Jalandoni and Santiago Yap—and NAMAWU-PAFLU. Lakas ng Manggagawang Makabayan (ALU) won. Subsequently, on November 13, 1967, Marinduque and Lakas ng Manggagawang Makabayan (ALU) executed a new collective bargaining agreement effective November 1, 1967.

ISSUE

Whether the appeal should be dismissed on the ground that the case has become moot and academic due to supervening events, namely the certification election and the execution of a new collective bargaining agreement.

RULING

The Supreme Court dismissed the case as moot and academic. The Court held that since the certification election resulted in a new union, Lakas ng Manggagawang Makabayan (ALU), winning and subsequently entering into a new collective bargaining agreement with Marinduque, the original dispute between PAFLU and NAMAWU-PAFLU over the check-off dues under the old agreement no longer presented a justiciable controversy. Resolving the questions raised in the appeal, including the jurisdictional issue of whether a court of first instance has jurisdiction over matters involving the internal organization of labor unions, would serve no useful purpose. The case was dismissed without costs.