Ortiz v. Commission on Elections
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of certificates of candidacy filed by respondents Primitivo R. Pasta and others. The petitioner, Francisco Ortiz, alleged that these certificates failed to comply with Section 32 of the Revised Election Code, as amended by Republic Act No. 3522, by omitting a required waiver of the privilege from public disclosure of their income tax returns and tax census statements for the years 1961 and 1962. Procedural History: The petitioner initially filed a petition with the Commission on Elections (COMELEC) seeking to declare the certificates of candidacy invalid on these grounds. The COMELEC, in a resolution dated October 17, 1963, denied this petition. Instead of invalidating the certificates, the COMELEC advised the respondents to file amended certificates of candidacy that included the required waiver, even though the statutory period for filing such certificates had already lapsed. The Petition: Francisco Ortiz subsequently filed a petition for review with the Supreme Court, seeking to annul the resolution of the Commission on Elections. The Supreme Court, on February 10, 1967, issued a resolution requiring Ortiz to show cause why the petition should not be dismissed, considering the possibility that the respondents had not been elected in the 1963 elections, which would render the case moot. In response, on March 14, 1967, Ortiz filed a manifestation and motion to dismiss his own petition for review, which the Supreme Court granted without costs.
Issue(s)
Whether the petition for review should be dismissed on the ground that the challenge to the respondents' certificates of candidacy has become moot and academic.
Ruling
The Supreme Court granted the motion for dismissal of the petition for review, without costs.
Ratio Decidendi
On Issue 1: The Supreme Court determined that the case should be dismissed because it had become moot and academic. This conclusion was based on the recognition that the 1963 elections had already concluded, and the respondents in the case were likely not elected to the offices they sought. Under Philippine Remedial Law, judicial power is only exercised when there is an actual case or controversy involving a conflict of legal rights. When a case is rendered moot, a judgment would provide no practical relief to the parties and would merely be an academic exercise. In this instance, the petitioner himself recognized the futility of proceeding with the case by filing a motion to dismiss. Consequently, as there was no longer a justiciable controversy regarding the validity of the certificates of candidacy, the Court dismissed the petition.
Main Doctrine
The Supreme Court dismissed the petition for review as moot and academic upon the petitioner's motion, considering the possibility that the respondents may not have been elected in the 1963 elections.