Jaro v. Isiderio
REITERATIONFacts
The Antecedents: Petitioner Antonio C. Jaro, the Vice Mayor of Tacloban City, alleged that respondent Councilor Rosario P. Isiderio filed a petition for injunction before the Court of First Instance (CFI) of Leyte. The CFI petition sought to enjoin Vice Mayor Jaro from assuming the position of city mayor should the incumbent Mayor Artemio F. Mate vacate the office upon filing his certificate of candidacy for Congressman. Isiderio claimed to be a "sure appointee" to the mayoralty, and that his succession would violate Section 21, paragraph b, of the Revised Election Code, as the incumbent mayor belonged to the Nacionalista Party while Isiderio was a Liberal Party councilor. Procedural History: The CFI granted the preliminary writ of injunction prayed for by respondent Isiderio. The Petition: Petitioner Jaro filed a petition for certiorari before the Supreme Court, assailing the CFI's issuance of the preliminary injunction. He argued that Isiderio had no cause of action and that the writ was illegal due to the violation of the Revised Election Code. Jaro contended that a motion for reconsideration before the CFI would cause unnecessary delay, prompting the direct resort to the Supreme Court. The Supreme Court issued an injunction restraining the respondents from carrying out the CFI's writ.
Issue(s)
Whether the petition for certiorari has become moot and academic due to supervening events. Whether the Court of First Instance gravely abused its discretion in issuing the writ of preliminary injunction.
Ruling
The Supreme Court dismissed the petition for certiorari, holding that the case had become moot and academic. The Court noted that respondents averred that petitioner Jaro had already assumed the Office of Mayor of Tacloban City on September 11, 1965, rendering moot and academic the injunction case filed by respondent Isiderio before the CFI. Consequently, the petition before the Supreme Court also became moot and academic.
Ratio Decidendi
On Whether the petition for certiorari has become moot and academic due to supervening events: The Supreme Court found that the petition had indeed become moot and academic. The respondents' averments, which were not disputed by the petitioner, indicated that Vice Mayor Antonio C. Jaro had already assumed the position of Mayor of Tacloban City on September 11, 1965. This supervening event effectively rendered the original petition for injunction filed by Councilor Rosario P. Isiderio before the Court of First Instance of Leyte moot and academic. Consequently, the petition for certiorari before the Supreme Court, which sought to annul the injunction issued by the CFI, also lost its purpose and relevance. The Court reiterated the principle that it will not pass upon issues that have already been resolved by supervening events, as such cases no longer present a justiciable controversy. On Whether the Court of First Instance gravely abused its discretion in issuing the writ of preliminary injunction: While the petition for certiorari was filed to question the alleged grave abuse of discretion of the CFI in issuing the writ of preliminary injunction, the Supreme Court did not delve into the merits of this issue. The dismissal of the case on the ground of mootness precluded any substantive ruling on the propriety of the injunction. The Court's resolution was based solely on the fact that the underlying controversy had been resolved by subsequent events, making it unnecessary to pass upon the legality or illegality of the preliminary injunction issued by the lower court. The assumption of office by the petitioner as mayor rendered the question of whether he should be enjoined from doing so moot.
Main Doctrine
The Supreme Court dismissed the petition for certiorari, finding that the issues raised had become moot and academic due to supervening events. Specifically, the petitioner having assumed the position of city mayor rendered the original injunction case moot, and consequently, the certiorari petition challenging the injunction also became moot.