G.R. No. L-37452 November 29, 1974
Union of Supervisors in Litex (USIL), petitioner, vs. The Court of Industrial Relations, Association of Democratic Labor Organizations (ADLO), and Labor Relations Division, Bureau of Labor Relations, Department of Labor, respondents.

FACTS

The Association of Democratic Labor Organizations (ADLO) filed a petition with the Court of Industrial Relations (CIR) to be certified as the exclusive bargaining agent for supervisors at Lirag Textile Mills, Inc. (Litex). The Union of Supervisors in Litex (USIL) and other groups intervened, opposing the petition. The proceedings focused on determining the appropriate bargaining unit, specifically whether purely confidential employees and top management personnel could be included among the eligible supervisors for the certification election. The CIR, through Judge Ansberto P. Paredes, issued an order directing the Department of Labor to conduct a certification election, excluding confidential employees and certain managerial personnel. USIL filed motions for reconsideration, which the CIR denied.
USIL then filed the instant petition for certiorari and prohibition before the Supreme Court, assailing the CIR’s orders. Notably, USIL raised for the first time the issue of the CIR’s jurisdiction, contending that Presidential Decree No. 21, which created the National Labor Relations Commission (NLRC), had vested exclusive jurisdiction over certification cases in the NLRC. The respondents were divided on this jurisdictional question, with the Bureau of Labor Relations agreeing with USIL, while the CIR and ADLO initially insisted on the CIR’s continuing jurisdiction.

ISSUE

The primary issue was whether the Court of Industrial Relations retained jurisdiction to hear and decide the certification election case after the promulgation of Presidential Decree No. 21.

RULING

The Supreme Court dismissed the case as moot. The legal logic centered on the effect of subsequent laws and directives that fundamentally altered the jurisdictional landscape. The Court noted that Letter of Instructions No. 191, issued on June 3, 1974, explicitly instructed the CIR—which was being phased out—to transfer all pending cases filed after October 14, 1972 (the date of PD No. 21) to the Bureau of Labor Relations. This directive rendered the specific controversy over the CIR’s contested orders academic. Furthermore, during the proceedings, counsel for ADLO conceded that the NLRC had jurisdiction over certification cases, and all parties subsequently filed manifestations acknowledging that the jurisdictional issue had been rendered moot by the said Letter of Instructions.
The Court also addressed ADLO’s desire for a ruling on the substantive issue of whether purely confidential and top management employees could join a supervisors’ union. It found this issue similarly mooted by the impending effectivity of the Labor Code (Presidential Decree No. 442), Article 292 of which expressly rendered managerial officials ineligible to join labor organizations. Consequently, the Court dismissed the petition without prejudice to ADLO’s right to institute a new appropriate proceeding before the Bureau of Labor Relations under the governing provisions of the new Labor Code.