GR L 50336; (July, 1985) (Digest)
G.R. No. L-50336 July 5, 1985
NATIONAL UNION OF GARMENTS TEXTILE CORDAGE AND GENERAL WORKERS OF THE PHILIPPINES (GATCORD), petitioner, vs. MINISTRY OF LABOR, BUREAU OF LABOR RELATIONS, GELMART WORKERS UNION, NATIONAL FEDERATION OF LABORS UNION (NAFLU), FEDERATION OF FREE WORKERS (FFW) AND TRADE UNIONS OF THE PHILIPPINES AND ALLIED SERVICES (TUPAS), respondents.
FACTS
The case originated from a petition for certification election filed by the Trade Unions of the Philippines and Allied Services (TUPAS) for the rank-and-file employees of Gelmart Industries (Phils.) Inc. The Med-Arbiter ordered a certification election with several contending unions, including the petitioner National Union of Garments Textile Cordage and General Workers of the Philippines (GATCORD) and the newly formed Bagong Pilipino Gelmart Workers Union (BPGWU). GATCORD appealed this order to the Bureau of Labor Relations (BLR), objecting to the inclusion of BPGWU as a contending party. GATCORD’s objection was based on a pending unfair labor practice charge it had filed against BPGWU and the company, alleging that BPGWU was a company-dominated union. GATCORD argued that this charge constituted a prejudicial question that should suspend the certification election proceedings until resolved.
The BLR denied GATCORD’s appeal and affirmed the Med-Arbiter’s order for a certification election, also allowing the intervention of the Federation of Free Workers (FFW). GATCORD’s motion for reconsideration was likewise denied. Consequently, GATCORD filed the instant petition for certiorari, seeking to annul the BLR’s resolutions and to enjoin the holding of the certification election, primarily on the ground that the unfair labor practice charge against BPGWU rendered the election proceedings premature.
ISSUE
Whether the petition for certiorari assailing the order for a certification election should be granted.
RULING
The Supreme Court dismissed the petition for being moot and academic. The legal logic is grounded on the principle that courts will not adjudicate cases where no practical relief can be granted. The records established that the factual circumstances underlying the petition had been overtaken by subsequent events. First, the unfair labor practice charge, which GATCORD claimed was a prejudicial question, had already been dismissed by the Labor Arbiter in a decision dated April 25, 1979. GATCORD did not appeal this dismissal, rendering it final. Second, and more decisively, the certification election that GATCORD sought to prevent had already been conducted on May 10, 1979, during the pendency of this petition. In that election, BPGWU won by a great majority and was subsequently certified as the sole and exclusive bargaining agent. The parties had even concluded a collective bargaining agreement effective until December 31, 1982.
Therefore, any ruling on the propriety of the BLR’s order to hold an election would be an abstract pronouncement, as the election had long been completed and its results implemented. The Court emphasized the settled doctrine that it will not determine moot questions where its decision would serve no useful purpose or provide any actual relief to the petitioner. Since the certification election was a fait accompli and the bargaining agent had been duly certified, the petition was rendered without any justiciable controversy.