G.R. No. L-25346 August 21, 1979
UNITED PHILIPPINE LINES, INC., petitioner, vs. HON. ARSENIO I. MARTINEZ, EMILIANO C. TABIGNE, AND ANTANDO C. BUGAYONG, Judges of the Court of Industrial Relations and UNITED STEEL WORKERS ASSOCIATION OF THE PHILIPPINES, respondents.

FACTS

United Philippine Lines, Inc. (petitioner) filed this petition for certiorari to nullify an order from the defunct Court of Industrial Relations (CIR). The CIR order had certified the United Steel Workers Association of the Philippines (USWAP) as the sole and exclusive bargaining agent for certain workers. Petitioner argued this certification was arbitrary, contending the workers in question were employees of an independent contractor and not direct employees of the shipping line. The petition was given due course, and petitioner filed its brief, but the respondent union did not submit any pleading in response.
After the case was pending, the Supreme Court issued a resolution inquiring if the matter had become moot and academic. Petitioner filed a manifestation stating it remained in the overseas shipping business with one vessel. However, it admitted it no longer operated the specific vessels involved in the dispute at the relevant time, though it had future plans to acquire or charter vessels that might require tank cleaners’ services. The private respondent USWAP maintained complete silence and showed no interest in the proceedings.

ISSUE

Whether the petition for certiorari assailing the certification order has been rendered moot and academic.

RULING

Yes, the petition is dismissed for being moot and academic. The Supreme Court applied the well-settled doctrine that courts will not determine a moot case where no actual substantial relief can be granted. The legal logic rests on the factual admissions and circumstances that removed any live controversy. Petitioner itself admitted it no longer operated the vessels central to the certification dispute. Consequently, the petitioner’s fear that USWAP would be considered the exclusive bargaining agent for those specific workers is illusory, as the employment relationship pertaining to those vessels has ceased.
Furthermore, the respondent union’s manifest lack of interest, evidenced by its failure to file any pleading or respond to the Court’s inquiries, reinforces the absence of a genuine adversarial issue requiring judicial resolution. No practical legal effect can flow from a ruling on the certification order under these defunct operational circumstances. The Court also noted that petitioner suffered no prejudice, as the execution of the challenged CIR order had been stayed upon posting a bond. Any future certification question involving new vessels would be governed under the then-new Labor Code, not the old order. Therefore, the Court declined to rule on the substantive issue, as any decision would be academic and ineffectual.