FERROTECH INDUSTRIAL ENGINEERING, INC.,MACALINO, F.S., AND PETITIONER VS. NATIONAL LABOR RELATIONS PROMULGATED: COMMISSION (FIFTH DIVISION), ET AL., MAY 20, 2014 RESPONDENTS.

Ferrotech Industrial Engineering versus National Labor Relations Commission

The Case

This is Ferrotech Industrial Engineering versus the National Labor Relations Commission, a labor case that reached the Supreme Court by petition for certiorari. The petitioner, Ferrotech Industrial Engineering, asked the Court to reverse the rulings of the labor tribunals against it. The case matters to a reviewee less for a grand doctrinal pronouncement than for what the Court actually did with it: the petition was withdrawn on the strength of a compromise agreement and a joint motion to dismiss filed before the labor commission, and the Court closed the case. It is a study in how a settlement can end litigation and in how the Court disposes of a petition once the parties have composed their differences.

Procedural History

The dispute was litigated before the labor tribunals, and the National Labor Relations Commission, through its Fifth Division, rendered the ruling that the petitioner sought to challenge. Ferrotech then came to the Supreme Court by a petition for certiorari, asking the Court to review and reverse the commission's action. While the petition was pending, the parties entered into a compromise agreement and filed a joint motion to dismiss before the National Labor Relations Commission. On the basis of that settlement, the petitioner, through counsel, filed with the Supreme Court a motion for leave to withdraw the petition for certiorari, attaching the compromise agreement and the joint motion to dismiss. The Court acted on that motion in its decision promulgated in May 2014.

Facts

Ferrotech Industrial Engineering was the petitioner in a labor dispute that was decided against it by the National Labor Relations Commission, Fifth Division. Aggrieved, Ferrotech elevated the matter to the Supreme Court through a petition for certiorari.

While the petition was pending, the parties chose to settle rather than continue litigating. They executed a compromise agreement and submitted it, together with a joint motion to dismiss, to the National Labor Relations Commission.

Consistent with that settlement, the petitioner, through counsel, filed before the Supreme Court a motion for leave to withdraw the petition for certiorari. The motion was supported by the compromise agreement and the joint motion to dismiss, which the Court noted had been submitted by the parties to the labor commission.

Issues

• Whether or not the petitioner's motion for leave to withdraw the petition for certiorari should be granted.
• Whether or not the case should be considered closed and terminated in view of the compromise agreement and the joint motion to dismiss submitted by the parties to the National Labor Relations Commission.

Applicable Provisions

The decision text before us does not quote or construe any statutory or constitutional provision. It rests entirely on the procedural posture created by the parties' compromise agreement and joint motion to dismiss. No verbatim provision is therefore reproduced here, and a reviewee should not attribute any quoted text to this decision.

Ruling

On the first issue, the Court granted the motion for leave to withdraw the petition for certiorari. It found the motion to be in order and supported by the compromise agreement and the joint motion to dismiss, which the parties had submitted to the National Labor Relations Commission. The Court's action rested on the parties' own settlement rather than on a review of the merits of the labor commission's ruling.

On the second issue, the Court declared the petition withdrawn and the case closed and terminated. It directed that an entry of judgment be issued. The dispositive portion states:

WHEREFORE, this petition is deemed WITHDRAWN and this case is now considered CLOSED and TERMINATED. Let Entry of Judgment be issued. SO ORDERED.

Justices Macalino and Corales concurred. The Court did not reach, and did not resolve, the substantive labor questions that the petition had raised, because the withdrawal and the settlement removed the controversy from its hands.

Doctrine

A Bar candidate should retain these rules from the case. First, a party who has settled the dispute may withdraw its petition for certiorari, and once the Court grants the withdrawal, the petition is deemed withdrawn and the case is closed and terminated. Second, a compromise agreement and a joint motion to dismiss submitted by the parties to the labor commission furnish the basis for such a withdrawal, and the Court will act on the motion when it is in order and duly supported. Third, when the Court closes a case on this ground, it does not rule on the merits of the challenged labor ruling; the settlement, not adjudication, ends the controversy. Fourth, the closure is final and is accompanied by an entry of judgment.

Disposition

The Court granted the motion for leave to withdraw the petition for certiorari, deemed the petition withdrawn, considered the case closed and terminated, and ordered that an entry of judgment be issued.

Remember This

The line worth memorizing is that a petition deemed withdrawn on the strength of a compromise agreement leaves the case closed and terminated, with an entry of judgment to follow. Examiners use this case to test how a settlement before the labor commission ends a pending Supreme Court petition without any ruling on the merits.