National Resettlement & Rehabilitation Administration v. Makasiar
REITERATIONFacts
The Antecedents: Respondents Lucio Lopez, Feliciano Tadeo, Pacita Eslaya Vda. de Valino, and Hilario Espiritu, as registered owners, filed possessory actions against occupants of parcels of land. These parcels were originally part of Hacienda del Rosario and were purchased by the plaintiffs from the former owner. The lower court ruled in favor of the plaintiffs, and this Court affirmed the judgments on appeal, which became final and executory on April 17, 1954. Procedural History: Proceedings for the execution of the judgments were suspended due to Republic Act No. 1266, which authorized the National Resettlement and Rehabilitation Administration (NARRA) to expropriate Hacienda del Rosario. NARRA filed a condemnation case (Civil Case No. 2006) for the expropriation of the Hacienda, including portions already sold to the plaintiffs in the possessory actions. However, the lower court dismissed the condemnation proceedings for a 230-hectare portion, including the lots in question, because it had already been partitioned. The lower court then ordered the execution of the judgments in the possessory actions, granting defendants until March 10, 1958, to vacate. Despite delays, the lower court granted defendants a final extension until February 22, 1959, to remove their houses, prompting NARRA to file the present petition. The Petition: The National Resettlement and Rehabilitation Administration (NARRA) filed a petition for prohibition with injunction to prevent the execution of the final judgments in Civil Cases Nos. 814, 815, 896, and 950. NARRA contended that executing these judgments before the final disposition of its appeal in the expropriation case (G. R. No. L-14111) would render its authority under Republic Act No. 1266 ineffectual should its appeal be sustained.
Issue(s)
Whether the petition for prohibition with injunction filed by NARRA should be granted to enjoin the execution of final judgments in possessory actions pending appeal of a related expropriation case. Whether the issues raised in the petition have become moot and academic.
Ruling
The petition is dismissed, without costs. The issues raised have become moot and academic due to a supervening event.
Ratio Decidendi
On Issue 1: The Court found it unnecessary to delve into the merits of the petition for prohibition with injunction. This was because, during the pendency of the petition before the Supreme Court, a decision was promulgated in G. R. No. L-14111, which was the appeal filed by NARRA from the decision in the expropriation case (Civil Case No. 2006). The decision in G. R. No. L-14111 affirmed the lower court's dismissal of the condemnation proceedings concerning the portions of Hacienda del Rosario that had already been sold or assigned to various individuals, including the parcels involved in the possessory actions. Therefore, the core issue that NARRA sought to prevent – the execution of judgments based on the fact that the land was still subject to expropriation – was rendered moot by the affirmation of the dismissal of the expropriation. On Issue 2: The Court explicitly declared that the issues raised in the present petition had become moot and academic. This declaration was a direct consequence of the supervening event, namely, the promulgation of the decision in G. R. No. L-14111 on October 24, 1960. In that decision, the Supreme Court affirmed the dismissal of NARRA's expropriation case concerning the disputed parcels of land. Consequently, the basis for NARRA's petition to enjoin the execution of the possessory judgments – the pendency and potential success of its expropriation appeal – no longer existed. The Court's pronouncement that the issues were moot and academic signifies that there was no longer a justiciable controversy to resolve, as the underlying dispute had been definitively settled by the related appellate decision.
Main Doctrine
A petition for prohibition with injunction seeking to enjoin the execution of a judgment becomes moot and academic when, during the pendency of the petition, the Supreme Court promulgates a decision on a related appeal that affirms the lower court's dismissal of expropriation proceedings, thereby resolving the core issues and rendering the relief sought in the petition unnecessary.