Calalang v. Medina
REITERATIONFacts
1. The Antecedents: Consuelo S. Calalang was granted a franchise by Republic Act No. 2290 to operate an ice plant and cold storage in Hagonoy, Bulacan. Aurora Tanjangco, administratrix of her deceased husband's estate, who operated an existing ice plant in the same town, applied to increase her plant's capacity. Calalang objected to this increase and sought a joint hearing for both her franchise application and Tanjangco's capacity increase application. 2. Procedural History: The Public Service Commission (PSC) initially denied Calalang's opposition and motion for a joint hearing. Calalang appealed this to the Supreme Court (L-16068), which reversed the PSC's order, mandating a joint trial of both cases and setting aside the prior decision on Tanjangco's capacity increase. Despite this, the PSC later denied Calalang's application for her franchise. Calalang filed a motion for reconsideration, which remained unresolved for an extended period. 3. The Petition: Calalang filed a petition for mandamus with the Supreme Court, seeking to compel the PSC Commissioners to act on her pending motion for reconsideration and supplemental motion for reconsideration in her franchise application case (PSC Case No. 126911). She also sought damages for alleged losses incurred due to the delay. While the petition was pending, the PSC eventually set aside its previous decision and scheduled a joint trial, rendering the mandamus aspect of the petition moot. However, Calalang pressed her claim for damages, which the Court found premature and impossible to ascertain without a final judgment on her franchise.
Issue(s)
Whether the Supreme Court can pass upon the claim for damages when the principal action for mandamus has become moot. Whether the respondents are liable for damages allegedly suffered by the petitioner due to undue delay in the resolution of her motions before the Public Service Commission.
Ruling
The petition for mandamus was dismissed as moot. The Court declined to pass upon the claim for damages, stating that it was debatable whether it could entertain the claim once the principal action had become moot, and further noting that the amount of damages was not yet ascertainable and legally impossible to determine without a final judgment fixing the conditions of operation for the ice plant.
Ratio Decidendi
On Whether the Supreme Court can pass upon the claim for damages when the principal action for mandamus has become moot: The Court held that the claim for damages was incidental to the petition for mandamus. It was considered debatable whether the Court could pass upon the incidental claim once the principal action for mandamus had become moot. The Court noted that without the principal action for mandamus, it would have no original jurisdiction to entertain the claim for damages. Therefore, the claim for damages was dismissed along with the mooted petition for mandamus. On Whether the respondents are liable for damages allegedly suffered by the petitioner due to undue delay in the resolution of her motions before the Public Service Commission: The Court found that there was no means by which to ascertain the amount of damages allegedly sustained by the petitioner, assuming the respondents could be held liable. The Court emphasized that unless and until a final judgment had been rendered fixing the conditions under which the petitioner could operate her ice plant and cold storage, particularly its capacity, it was legally impossible to determine the amount of damages. Consequently, the claim for damages could not be granted.
Main Doctrine
The Supreme Court reiterated that a petition for mandamus is an action to compel the performance of a ministerial duty. When the primary action for mandamus becomes moot, any incidental claim for damages may also be rendered moot or unresolvable, particularly if the damages are not yet ascertainable and depend on the outcome of a final judgment. The Court emphasized that it would not pass upon such claims if the principal action, which grants it original jurisdiction over the incidental claim, is no longer viable.