G.R. No. 101766 - Borbon II vs. Laguesma

Background of the Case:

The case involves a dispute over the election of officers for the San Miguel Corporation Employees Union-PTGWO (SMCEU-PTGWO).
Petitioners Daniel S.L. Borbon II and Reynaldo D. Nicodemus contested the election results, particularly the positions of president and auditor, which were won by respondents Raymundo E. Hipolito, Jr. and Pablo Dee, respectively.

Election Agreement:

On December 5, 1990, representatives from various groups of the bargaining unit of monthly-salaried employees of San Miguel Corporation entered into a voluntary agreement. The agreement stipulated that:
- The election of officers would be conducted on December 14, 1990.
- Alleged contractual employees involved in a prior case (G.R. No. 87700) would be allowed to vote, but their ballots would be segregated subject to protest.
- If petitioner Borbon could present evidence that these employees were qualified union members, their votes would be unchallenged.

Submission of Union Membership Applications:

On December 10, 1990, petitioner Borbon submitted a list of applications for union membership, including 126 alleged contractual employees.
On December 12, 1990, the parties agreed that these contractual employees would be allowed to vote at the Magnolia Plant, Quezon City.

Election Day Events:

On December 14, 1990, as the 127 contractual employees prepared to vote, attorneys Raymundo Hipolito III and Jose F. Loy informed them they could not vote because they were not union members.
After petitioner Borbon intervened, DOLE officials allowed the employees to vote, but only 70 were able to cast their votes, which were segregated. The remaining 57 employees could not return to the polling place due to lack of transportation and time constraints.

Election Results:

The election results for president and auditor were as follows:
- President: Daniel S.L. Borbon II (706 votes), Raymundo Hipolito (789 votes).
- Auditor: Pablo Dee (568 votes), Reynaldo Nicodemus (532 votes).

Election Protest:

On December 18, 1990, petitioners Borbon and Nicodemus filed a protest, alleging:
- Many members were unable to vote because their names were not included in the voters' list.
- Contractual employees were not allowed to vote at the Magnolia Plant but were instructed to vote at the Head Office Complex, Mandaluyong.
- The ballots of contractual employees who voted were segregated and not counted.

Med-Arbiter's Order:

On December 28, 1991, the med-arbiter issued an order directing that the 57 contractual employees be allowed to vote, and their votes, along with the 70 segregated ballots, be canvassed to determine the winners for president and auditor.

Appeals and Decision:

Petitioner Borbon filed a partial motion for reconsideration, while respondent Hipolito filed a motion for reconsideration, both treated as appeals by the Undersecretary of Labor and Employment.
On July 26, 1991, the Undersecretary denied Borbon's partial appeal and granted Hipolito's appeal, modifying the med-arbiter's order. The 57 contractual workers were not allowed to vote, and the 70 challenged votes were not opened or canvassed. Hipolito and Dee were proclaimed as the duly elected president and auditor, respectively.

Subsequent Developments:

Petitioners filed a motion for reconsideration, which was denied on September 2, 1991.
The case was elevated to the Supreme Court via a special civil action for certiorari.

Mootness of the Case:

Private respondents informed the Court that Magnolia had ceased to be a division of San Miguel Corporation and had been formed into a separate corporation. This development rendered the issue of the election moot and academic.

Mootness Doctrine: The Court applied the mootness doctrine, which holds that a case becomes moot when it no longer presents a justiciable controversy because the issues involved have become academic or dead. The separation of Magnolia from San Miguel Corporation rendered the election dispute moot, as the employees in question were no longer connected with San Miguel Corporation.
Proper Handling of Election Protests: The Court implicitly upheld the Undersecretary's decision, which was based on the evidence and agreements made prior to the election. The Undersecretary's ruling that the 57 contractual employees should not be allowed to vote and that the 70 challenged votes should not be opened or canvassed was deemed proper under the circumstances.
Finality of Administrative Decisions: The Court affirmed the finality of administrative decisions, particularly those of the Department of Labor and Employment, when they are supported by substantial evidence and are in accordance with the law.