G.R. No. 155097 - Philippine Airlines Employees Association vs. Cacdac

PALEA was the sole and exclusive bargaining representative for all regular rank-and-file employees of Philippine Air Lines.
The organization held a general election for new officers after the five-year term of its 1995-elected officers expired.
The election was conducted by a Comelec formed by a chairman and two members appointed by the incumbent president with the concurrence of three-fourths of the Board of Directors.

After the casting and canvassing of votes, the Comelec proclaimed the winners.
On June 15, 2000, the BLR Regional Director nullified the election and proclamation based on allegations of fraud and irregularities.
The nullification prompted the ordering of a new general election under the direct supervision of the Department of Labor and Employment (DOLE).

On July 28, 2000, the BLR Director of the National Capital Region affirmed the nullification through a resolution.
A petition for certiorari was filed by Jose PeAas III in the Court of Appeals (CA) challenging the July 28, 2000 resolution.
On March 28, 2001, the CA dismissed the petition and upheld the order to conduct another general election to resolve the leadership issue definitively.

Pre-Election Proceedings and the Petition to Amend PALEA’s Constitution and By-Laws

During DOLE’s pre-election proceedings, some PALEA members petitioned for a plebiscite to amend its Constitution and By-Laws to secure representation on its Board of Directors.
The filing of the petition led the BLR to suspend the pre-election conference until the amendment issue was resolved.
On February 15, 2002, the BLR Regional Director dismissed the plebiscite petition and ordered the immediate conduct of the general election.

PALEA, represented by its holdover president Alexander O. Barrientos, filed a petition for certiorari challenging the February 15, 2002 order and a subsequent February 27, 2002 letter from the BLR Director.
The petition alleged grave abuse of discretion and questioned the manner in which the election was conducted under DOLE supervision.
A temporary restraining order (TRO) was issued by the CA on the day of the election, but it was received by the Comelec after the polls had closed.
The CA ultimately dismissed PALEA’s petition and ordered the continuation of the canvass of the election results as the election had already been substantially completed.

Whether PALEA’s petition for certiorari was appropriate given that the election results were already final or nearly so.
Whether PALEA should have awaited the final certification of the election before resorting to a petition for certiorari.

Whether the Regional Director and the BLR Director were exercising quasi-judicial functions or merely performing ministerial acts in enforcing the BLR resolution.

Whether the conduct of the election under DOLE supervision, as well as the implementation of the BLR resolutions, complied with the PALEA Constitution and By-Laws and the applicable rules on the election of union officers.
Whether PALEA’s arguments against the election procedures provided sufficient grounds to nullify the election results.