Case Summary (G.R. No. 155097)
Antecedents of the Case
PALEA served as the exclusive bargaining representative for regular rank-and-file employees at Philippine Airlines. Following the expiration of its officers' terms in 1995, PALEA held elections for new officers in February 2000. However, a resolution on June 15, 2000, from the Regional Director of the Bureau of Labor Relations nullified the elections due to allegations of fraud and irregularities, mandating a new election under the supervision of the Department of Labor and Employment (DOLE).
Appeals and Legal Proceedings
The Regional Director's decision was upheld by the BLR Director on July 28, 2000, leading to a legal challenge from the proclaimed president, Jose Peñas III, who sought annulment of this resolution. The Court of Appeals confirmed the necessity of a new election on March 28, 2001. Following this, the DOLE commenced pre-election procedures but faced interruptions due to a petition from PALEA members seeking to amend the association's Constitution, which was ultimately dismissed by the BLR Regional Director on February 15, 2002.
Contention Leading to Certiorari
In response to the dismissal of the appeal against the February 15 order, PALEA filed a petition for certiorari on the grounds of grave abuse of discretion, seeking to prevent the scheduled election on April 5, 2002. On the day of the election, the Court of Appeals granted a temporary restraining order (TRO), but it was received too late to halt the election proceedings.
Court of Appeals' Dismissal and Rationale
The Court of Appeals dismissed PALEA's petition for lack of merit, emphasizing that the petition did not properly address the earlier rulings but instead attempted to forestall the already mandated election process. The Court highlighted that the petition aimed to dispute procedural aspects of the election rather than the substantive issue at hand, which was the necessity of conducting a new election as ordered by prior legal judgments.
Analysis of Legal Parameters and Findings
The Supreme Court's subsequent review found that PALEA's petition did not meet the necessary legal requisites for certiorari, namely that the petition must involve an authentic exercise of judicial or quasi-judicial functions, which was not present in the act
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Case Information
- Citation: 645 Phil. 494
- Division: Third Division
- Docket Number: G.R. No. 155097
- Date of Decision: September 27, 2010
Parties Involved
- Petitioner: Philippine Airlines Employees Association (PALEA), represented by Alexander O. Barrientos
- Respondents:
- Hon. Hans Leo J. Cacdac (Director of Bureau of Labor Relations)
- Hon. Alexander Maraaan (Regional Director, National Capital Region)
- Cynthia J. Tolentino (Representation Officer, Labor Relations Division, National Capital Region, Department of Labor and Employment)
- Nida J. Villagracia
- Dolly Ocampo
- Gerardo F. Rivera (in their respective capacities as candidates for president of petitioner PALEA)
Antecedents
- PALEA was recognized as the exclusive bargaining representative for all regular rank-and-file employees of Philippine Airlines.
- Following the expiration of its officers' five-year term in 1995, PALEA conducted general elections for new officers from February 17 to 24, 2000.
- A Commission on Elections (Comelec) was formed to oversee the election, leading to the proclamation of winners.
- On June 15, 2000, the Regional Director of the Bureau of Labor Relations (BLR) nullified the election results due to alleged fraud and irregularities, ordering a new election under the supervision of the Department of Labor and Employment (DOLE).
- The BLR Director's decision was affirmed on July 28, 2000, and subsequent appeals were made, including a petition for certiorari to the Court of Appeals (C.A.-G.R. SP No. 60886) which was dismissed on March 2