G.R. No. L-34688. August 30, 1972.
PHILIPPINE CHARITY SWEEPSTAKES EMPLOYEES ASSOCIATION-PAFLU, ET AL., petitioners, vs. COURT OF INDUSTRIAL RELATIONS and PHILIPPINE CHARITY SWEEPSTAKES OFFICE, respondents.

FACTS

The petitioners, a labor union and its individual members, filed an urgent petition for a preliminary mandatory injunction before the Court of Industrial Relations (CIR). After more than four months of inaction by the CIR en banc on their motion, the petitioners filed the instant special civil action for mandamus with the Supreme Court. The sole objective of the petition was to compel the CIR to act, one way or another, on their pending urgent motion for injunction.
In its resolution, the Supreme Court required the respondents to comment. Only the Philippine Charity Sweepstakes Office (PCSO) filed a comment, which was treated as its answer. The CIR did not file any comment. The PCSO subsequently argued that the petition had been rendered moot and academic because, during the pendency of this case, the CIR en banc had already issued a Resolution on May 26, 1972, denying the petitioners’ motion for reconsideration of the trial court’s earlier order and, in effect, resolving the very urgent petition for injunction that was the subject of the mandamus.

ISSUE

Whether the petition for mandamus had been rendered moot and academic by the subsequent action of the respondent Court of Industrial Relations.

RULING

Yes, the petition is moot and academic. The Supreme Court declared the case moot because the act sought to be compelled—a resolution by the CIR en banc on the urgent petition for a preliminary mandatory injunction—had already been performed with the issuance of the CIR’s Resolution dated May 26, 1972. A mandamus proceeding becomes moot when the desired act has already been carried out, leaving no substantial issue for judicial determination.
However, the Court seized the opportunity to admonish the respondent Court of Industrial Relations for its undue delay and failure to act promptly on the labor union’s urgent motion. The Court emphasized that the CIR, as a special court created to implement labor laws effectively, has an affirmative and dynamic duty to act with promptitude and dispatch. Its functions are not passive like ordinary courts; it must avoid unnecessary delays that prejudice the rights of labor. The Court cited the doctrine in Ang Tibay v. Court of Industrial Relations, which characterizes the CIR as an active administrative body. The CIR’s inaction in this case, which necessitated the elevation of the matter to the Supreme Court, contravened this duty and could erode public confidence in its effectiveness. The Court expressed the expectation that the CIR would exercise greater care to fulfill its statutory obligations promptly in the future to avoid similar unnecessary proceedings. The petition was dismissed for being moot, without costs.