Case Digest (G.R. No. L-22508)
Facts:
The case of Floro Buenconsejo vs. The Court of Industrial Relations, Union Obrera de Tabaco, and Tito Bilangel (G.R. No. L-22508) arose from a petition filed by Floro Buenconsejo on February 26, 1964. Buenconsejo sought to participate in the upcoming biennial election for the presidency of the Union Obrera de Tabaco, scheduled for March 1, 1964. Prior to the election, he submitted his certificate of candidacy in accordance with the union's constitution and by-laws. However, on February 14, 1964, the union returned his certificate, stating that he could not participate in the election for unspecified reasons that were allegedly known to him. Concerned about rumors that Tito Bilangel would be the sole candidate and control the election, Buenconsejo filed a charge of unfair labor practice against the union and Bilangel on February 10, 1964. Following a preliminary investigation, the Acting Prosecutor, Atty. Linda Ilagan, filed a complaint for unfair labor practice. Given the...
Case Digest (G.R. No. L-22508)
Facts:
Election Context:
- The case involves the biennial election of officers of the Union Obrera de Tabaco, scheduled for March 1, 1964.
- Petitioner Floro Buenconsejo filed his certificate of candidacy for the presidency of the union in accordance with its constitution and by-laws.
Exclusion from Candidacy:
- On February 14, 1964, the union returned Buenconsejo’s certificate of candidacy, advising him that he could not participate in the election for unspecified reasons allegedly known to him.
Unfair Labor Practice Charge:
- On February 10, 1964, Buenconsejo filed a charge of unfair labor practice against the union and Tito Bilangel (the sole candidate for president) before the Court of Industrial Relations (CIR).
- The Acting Prosecutor, Atty. Linda Ilagan, filed a complaint for unfair labor practice after a preliminary investigation.
Urgent Petition for Injunction:
- Due to the proximity of the election, Buenconsejo filed an Urgent Petition for Preliminary Injunction on February 20, 1964, seeking to compel the union to include him as a candidate in the March 1, 1964 election.
- He filed multiple urgent motions for immediate resolution, but the CIR failed to act on his petition.
Petition for Mandamus:
- On February 26, 1964, Buenconsejo filed an original action for mandamus with preliminary injunction before the Supreme Court, seeking his inclusion as a candidate in the election.
- The Supreme Court issued a resolution on February 28, 1964, requiring the respondents to answer the petition and ordering the CIR to act on the complaint.
Election Held Without Petitioner:
- The election proceeded as scheduled on March 1, 1964, without Buenconsejo’s participation.
- Respondents argued that the issue had become moot and academic because the election had already taken place.
Failure to Post Bond:
- Buenconsejo’s inability to secure a writ of preliminary mandatory injunction was attributed to his failure to post the required bond.
Issue:
- Whether the petition for mandamus to compel the Court of Industrial Relations to act on Buenconsejo’s Urgent Petition for Preliminary Injunction is still viable after the union election had already taken place.
- Whether the issue raised by Buenconsejo has become moot and academic due to the completion of the election.
Ruling:
The Supreme Court dismissed the petition as moot and academic.
Ratio:
Mootness Doctrine:
- The Court held that the issue had become moot and academic because the union election had already been held on March 1, 1964, without Buenconsejo’s participation.
- There was no longer any justiciable controversy to resolve, as the relief sought (inclusion in the election) could no longer be granted.
Failure to Post Bond:
- The Court noted that Buenconsejo’s inability to secure a writ of preliminary mandatory injunction was due to his failure to post the required bond.
- This failure further underscored the lack of a legal basis to grant the relief sought.
No Justiciable Controversy:
- Since the election had already taken place, there was no live issue or controversy requiring judicial intervention.
- The Court emphasized that it does not adjudicate cases that no longer present an actual dispute.