GR L 30961; (January, 1975) (Digest)
G.R. No. L-30961. January 29, 1975.
DBP EMPLOYEES UNION-NATU, petitioner, vs. DEVELOPMENT BANK OF THE PHILIPPINES and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
The petitioner, DBP Employees Union-NATU, filed this case to challenge the validity of an act by the President of the Philippines withdrawing a certification of a labor dispute previously issued to the Court of Industrial Relations (CIR). The Union argued that once the President, under the Industrial Peace Act (Republic Act No. 875), had certified a labor dispute to the CIR for compulsory arbitration, the tribunal should be left to exercise its jurisdiction freely to settle the dispute. The President’s subsequent withdrawal of that certification was, therefore, an invalid interference.
The respondents, the Development Bank of the Philippines and the CIR, countered by invoking the broad executive power vested in the President by the Constitution. They contended that the presidential power to certify a labor dispute to the CIR inherently included the power to withdraw such certification. This authority was argued to be part of the President’s constitutional duty to ensure the faithful execution of laws, a principle supported by scholarly commentary.
ISSUE
The core legal issue is whether the President of the Philippines has the authority to withdraw a certification of a labor dispute after having referred it to the Court of Industrial Relations for compulsory arbitration.
RULING
The Supreme Court dismissed the petition for being moot and academic, rendering no definitive ruling on the substantive legal issue presented. The Court’s resolution was based on a significant change in the legal landscape that occurred while the case was pending. A new Labor Code, Presidential Decree No. 442, had been enacted in 1974. This Code abolished the Court of Industrial Relations, the very tribunal to which the disputed certification had been issued, and replaced it with the National Labor Relations Commission.
Crucially, the new Labor Code contained no provision for the presidential certification of labor disputes to the new commission. Since the institutional framework and the statutory basis for the act being challenged—the certification to the now-defunct CIR—had been entirely eliminated, any decision on the merits would be purely academic. The Court emphasized that it avoids issuing advisory opinions on hypothetical questions or moot controversies. Therefore, without a live case or controversy governed by the repealed law, the petition was dismissed. No costs were awarded.