Law School Noob: [CASE DIGEST] Dinio v. Laguesma

Sunday, August 11, 2013

[CASE DIGEST] Dinio v. Laguesma

June 9, 1997 | G.R. No. 108475

Gamaliel Dinion, Ernesto Mangahas, Edgar S. Vinson, and Party for Reform, petitioners
Hon. Bienvenido E. Laguesma, Undersecretary of the Department of Labor & Employment, The Committee on Election, Danilo Picadizo, national officers of the PCIBank Employees Union, members of the COMELEC-PCIBEU, respondents

FACTS:

The election of a new set of union officers for the PCIBank Employees Union (PCIBEU) was scheduled after the expiration of the terms of office of the incumbent officers. The election was between Party for Progress and Unity (PPU), with president Nandiego, and Party for Reform (PFR), whose standard bearer was petitioner Dinio.

The PCIBEU board through a Board Resolution, which was not signed by Dinio, formed a Committee on Election (COMELEC).

Two days before the elections, PFR filed with the BLR a petition for injunction with prayer for issuance of temporary restraining order against the COMELEC, on the grounds that: PCIBEUComelec was not validly constituted; that said committee failed to issue the necessary election guidelines; that official ballots were dispatched to the provincial branches without the knowledge of PFR; and that there is reasonable ground to believe that the elections will be rigged in favor of the other party.

Med-Arbiter granted the TRO.

On appeal, DOLE undersecretary Laguesma declared that the TRO issued by the Med-Arbiter had no force and effect. PFR failed to hurdle the test of “grave or irreparable damage.”

ISSUE:

Whether the TRO issued by the Med-Arbiter was valid – NO.

HELD:

The SC held that the TRO was void and that the elections were valid. In the case of labor injunctions or temporary restraining orders, one may issue only in instances where the complainant or applicant will suffer grave or irreparable damages.

The failure to show grave and irreparable injury, which happened in this case, counts as an exception to the general rule that the Med-Arbiter has discretion to issue TRO.

As to the 20-day rule, this still applies in labor cases pursuant to Article 225 of the Labor Code. Thus, the TRO was indeed invalid and consequently, the elections were deemed valid.

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