G.R. No. L-78061. November 24, 1988.
LITTON MILLS EMPLOYEES ASSOCIATION-KAPATIRAN AND ROGELIO ABONG, petitioners, vs. HON. PURA FERRER-CALLEJA, in her capacity as Director of the Bureau of Labor Relations, RODOLFO UMALI AND LITTON MILLS, INC., respondents.

FACTS

Petitioner Litton Mills Employees Association-Kapatiran (LMEA-K) is a legitimate labor organization at respondent Litton Mills, Inc. (LMI). Its president, respondent Rodolfo Umali, affiliated the union with the federation GATCORD on August 14, 1986, without the knowledge and approval of the general membership. A majority of the union members (725 out of roughly 1,100) subsequently opposed this affiliation through a written manifesto and authorized union vice-president Rogelio Abong to take action, including impeachment, against Umali. Despite this opposition, Umali continued to act on behalf of the affiliated union.
Consequently, the majority of union officers, led by Abong, initiated impeachment proceedings against Umali for disloyalty. A meeting was scheduled for Umali to answer the charges, but he failed to appear. The officers then voted to impeach him and requested LMI to terminate his employment under the union security clause of their Collective Bargaining Agreement (CBA). The company refused, stating the union must first comply with pertinent Department of Labor and Employment requirements. The Med-Arbiter and the Bureau of Labor Relations Director upheld the company’s position, ruling the impeachment invalid due to non-compliance with the union’s own impeachment procedures.

ISSUE

Whether the impeachment of union president Rodolfo Umali was valid and whether the company could be compelled to terminate him under the CBA’s union security clause.

RULING

The Supreme Court denied the petition, declaring the issues moot and academic. The Court found that the impeachment process was procedurally flawed. While the union constitution granted the general membership the power to impeach officers, it also outlined a specific procedure requiring a formal investigation by the union’s Executive Board. Petitioners failed to substantially comply with this procedure; they scheduled only one investigatory meeting and proceeded with impeachment immediately upon Umali’s non-appearance without affording him ample opportunity to defend himself.
More critically, a supervening event rendered the case moot. A group of employees, including petitioner Abong, had broken away from LMEA-K and formed a new union, the Litton Mills Workers Union. This new union won a subsequent certification election and was certified as the exclusive bargaining agent. This development clearly demonstrated that the majority of the former LMEA-K members no longer wished Umali to be their president or to be affiliated with GATCORD. The question of Umali’s status in the original union thus ceased to have practical legal significance. The Court emphasized that the will of the employees is best ascertained through a certification election, which had already been achieved. Therefore, the petition was dismissed.