Case Digest (G.R. No. 150334)
Facts:
Dolly A. Ocampo, Mario S. Verona, Isagani O. Dawal, Jose Arcadio R. Relova, Aristophane Palencia and Armando Hernandez v. The Honorable Court of Appeals (Former Second Division), Hon. Benedicto Ernesto R. Bitonio, Hon. Maximo B. Lim, Edgardo C. Oredina, and Philippine Airlines, Inc., G.R. No. 150334, March 20, 2009, Supreme Court Third Division, Nachura, J., writing for the Court.The dispute arose from the PALEA (Philippine Airlines Employees Association) general elections held on February 17, 21, 23 and 24, 2000, after the incumbents’ terms expired. The PALEA Commission on Elections (Comelec) segregated about 500 ballots (for cross-precinct voters) and questioned three ballot boxes from certain precincts pursuant to an internal circular; after canvassing, and without awaiting completion of further processes, the Comelec declared several candidates — including petitioners here — elected and proclaimed them in mid-March 2000.
On March 7, 2000, candidate Nida Villagracia filed a petition with DOLE-NCR (docketed NCR-OD-0003-004-IRD) asking DOLE to assume jurisdiction and complete the canvass; while that petition was pending, the Comelec’s proclamation occurred. Villagracia’s petition was dismissed on March 30, 2000 for prematurity and failure to exhaust internal remedies under Article XIX, Section VI of the PALEA Constitution and By‑laws. On March 30, 2000 private respondent Edgardo Oredina filed another petition (docketed NCR-OD-0003-010-IRD) to declare a failure of election and sought injunctive relief.
DOLE-NCR, through Director Maximo B. Lim, rendered a Decision dated June 15, 2000 nullifying the PALEA election and the Comelec proclamation, and ordered a new election under DOLE supervision. The Bureau of Labor Relations (BLR), through Director Benedicto Ernesto R. Bitonio, Jr., denied the appeal from that DOLE-NCR decision by Resolution dated July 28, 2000 and later denied motions for reconsideration by Resolution dated August 24, 2000. Only one of the proclaimed winners, Jose T. Penas III, filed a petition for certiorari with the Court of Appeals (CA), which affirmed the BLR in a Decision promulgated March 28, 2001 and denied reconsideration on October 12, 2001.
The present petition for review on certiorari under Rule 45 was filed in this Court on November 29, 2001 by the other proclaimed winners (petitioners here), who had been co‑respondents in the DOLE and BLR proceedings but had not joined Penas in his CA petit...(Pro-only)
Issues:
- Are petitioners, who were co-respondents in the DOLE-NCR and BLR proceedings but were not parties to the certiorari petition filed before the Court of Appeals, proper parties to file a petition for review on certiorari under Rule 45 to assail ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)