Corpuz v. Jimenez
REITERATIONFacts
1. The Antecedents: The underlying dispute involves an ejectment case filed by J.M. Tuason & Co. Inc. against Fernando Corpuz. The plaintiff alleged that Corpuz illegally entered and constructed a house on a portion of their land in Barrio North Tatalon, Quezon City, on December 1, 1957. 2. Procedural History: J.M. Tuason & Co. Inc. filed an ejectment complaint (Civil Case No. 4689) with the Municipal Court of Quezon City. After several postponements, and the failure of Corpuz and his counsel to appear on August 11, 1959, the court proceeded with the hearing, rendering a default judgment against Corpuz. A writ of execution was issued, and Corpuz's subsequent motion to lift it was denied. Corpuz then filed a petition for relief from judgment with the Court of First Instance of Rizal (Civil Action No. Q-4916), seeking to annul the Municipal Court's decision and denial order. The Court of First Instance denied this petition, leading to the present appeal. 3. The Petition: Fernando Corpuz, as plaintiff-appellant, is appealing the March 22, 1960 order of the Court of First Instance of Rizal, which denied his petition for relief from the judgment rendered by the Municipal Court of Quezon City. The appeal was originally filed with the Court of Appeals, where a motion to dismiss was filed on the grounds that the issues had become moot due to Corpuz voluntarily vacating the premises. The case was subsequently certified to the Supreme Court.
Issue(s)
Whether the appeal should be dismissed on the ground that the issues have become moot and academic due to the appellant's voluntary vacation of the premises. Whether the appellant's failure to answer the motion to dismiss constitutes acquiescence to the dismissal.
Ruling
The appeal is dismissed, without costs.
Ratio Decidendi
On Whether the appeal should be dismissed on the ground that the issues have become moot and academic due to the appellant's voluntary vacation of the premises: The Supreme Court noted that the appellee filed a motion to dismiss the appeal in the Court of Appeals, alleging that the appellant had voluntarily vacated the premises by removing his house and other constructions. This action by the appellant would render the issues raised in the appeal moot and academic, as there would no longer be any dispute regarding possession of the land. The Court of Appeals required the appellant to answer this motion, but the appellant failed to do so. Such failure to respond to a motion to dismiss, especially one based on the premise of mootness due to the appellant's own actions, is significant. On Whether the appellant's failure to answer the motion to dismiss constitutes acquiescence to the dismissal: The Supreme Court considered the appellant's failure to file an answer to the appellee's motion for dismissal as an implied acquiescence to the motion. In appellate proceedings, a party is expected to respond to substantive motions filed by the opposing party. When a motion to dismiss is filed, and the appellant, who is the one seeking relief from the lower court's decision, does not present any arguments or objections against it, it can be reasonably inferred that the appellant does not intend to pursue the appeal further or has no valid grounds to oppose the dismissal. Therefore, the Court took this failure as an indication that the appellant agreed with the appellee's contention that the case had become moot and academic.
Main Doctrine
The Supreme Court reiterated that an appeal can be dismissed if the subject matter of the case has been rendered moot and academic. This is particularly true when the appellant fails to actively pursue the appeal or respond to motions filed by the appellee, such as a motion to dismiss based on the voluntary vacation of the premises. Such inaction can be construed as acquiescence to the dismissal, thereby terminating the appellate proceedings.