GR L 35067; (October, 1972) (Digest)
G.R. No. L-35067. October 31, 1972.
TIP WORKERS UNION β NATU, ET AL., petitioners, vs. TOBACCO INDUSTRIES OF THE PHILIPPINES, INC., ET AL., and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
Petitioners, a union and its individual members, sought a review of a Court of Industrial Relations (CIR) decision dated January 1, 1972, which was later affirmed by the CIR en banc. The CIR had absolved respondent Tobacco Industries of the Philippines, Inc. from a charge of unfair labor practice. The charge stemmed from the dismissal of individual petitioners allegedly without notice and hearing, which the company justified under a maintenance of membership clause in the existing collective bargaining agreement. The petitioners contended this dismissal was illegal under prevailing Supreme Court doctrines.
In their petition to the Supreme Court, filed on May 12, 1972, the petitioners raised two primary legal questions. First, they challenged the validity of the CIR decision in light of applicable jurisprudence. Second, they questioned the legal effect of a subsequent memorandum agreement entered into by the parties, which they argued amounted to a condonation of a strike that had been previously declared illegal by the CIR. The Court gave due course to the petition on June 8, 1972, requiring answers from the respondents.
ISSUE
Whether the Supreme Court should dismiss the petition for review based on a joint motion filed by the parties indicating an amicable settlement.
RULING
Yes. The Supreme Court granted the joint motion and dismissed the case for being moot and academic. The legal logic is grounded in judicial policy and procedural rules. The core controversyβthe unfair labor practice charge regarding the dismissals and the related questions about the collective bargaining agreement and the memorandum agreementβwas rendered without practical legal effect by the subsequent actions of the parties themselves. Before the petitioners could even file their brief, both parties, duly represented by their respective counsel, submitted a “Joint Motion to Dismiss Appeal” dated September 28, 1972.
This motion explicitly stated that the parties had “amicably settled the above-entitled case to the mutual satisfaction of all concerned.” It invoked Section 4, Rule 50 of the New Rules of Court, which provides for the dismissal of an appeal upon such request. When parties to a litigation voluntarily settle their dispute, the original case or appeal typically loses its adversarial character and becomes moot. Courts generally do not adjudicate moot questions or issue advisory opinions, as any ruling would have no actual, concrete impact on the rights of the parties involved. The settlement extinguished the live controversy that originally prompted the appeal. Therefore, without any remaining justiciable issue to resolve, the Supreme Court had no alternative but to dismiss the petition. The dismissal was without costs, reflecting the consensual resolution reached by the parties.
