Dirampaten v. Alonto
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the suspension of Datu Mariga Dirampaten from his position as mayor of Taraka, Lanao del Sur. The suspension was initiated by the respondent Governor Hadji Madki Alonto based on an administrative complaint alleging oppression, corruption, and maladministration against the petitioner. 2. Procedural History: On September 23, 1965, Governor Alonto issued Administrative Order No. 2, suspending Mayor Dirampaten and designating the vice-mayor as acting mayor. The petitioner then filed a petition for certiorari, prohibition, and mandamus with this Court on October 4, 1965. A preliminary mandatory injunction was issued on October 6, 1965, restoring the petitioner to his position. The respondents filed their answer on November 23, 1965. The case was submitted for decision on February 2, 1966, due to the petitioner's non-appearance. Subsequently, in the November 14, 1967 elections, the petitioner was re-elected mayor, and the principal respondents did not seek re-election. 3. The Petition: The petitioner sought a writ of certiorari, prohibition, and mandamus to annul Administrative Order No. 2, declare the designation of the acting mayor illegal, enjoin the provincial board from continuing the investigation, and compel the Governor to follow proper investigative procedures. The petition argued that the Governor acted with grave abuse of discretion and in gross violation of law. The petitioner later filed a motion to withdraw the petition on February 6, 1968, asserting that the case had become moot and academic due to his re-election and the cessation of the respondents' terms in office.
Issue(s)
Whether the supervening events of the 1967 general elections, specifically the re-election of the petitioner and the cessation of office of the respondents, rendered the petition for certiorari, prohibition, and mandamus moot and academic.
Ruling
The Court granted the petitioner's motion to withdraw the petition, thereby dismissing the case.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petition had become moot and academic for all practical purposes due to the supervening change in the status of the parties. The Court noted that the principal respondents, Alonto and Sumpingan, ceased to hold their positions as Governor of Lanao del Sur and Vice-Mayor of Taraka following the November 1967 elections. Because Alonto was no longer the Governor, he could not be bound by a judgment regarding the administrative orders he issued during his tenure. Furthermore, the threat of Sumpingan assuming the mayoralty vanished with the expiration of his term as vice-mayor and his failure to seek re-election. The Court reasoned that any resolution of the petition would serve no useful purpose given that the legal controversy regarding the suspension and designation of an acting mayor had lost its practical relevance. Consequently, as the petitioner himself sought the withdrawal and no other parties would be prejudiced by it, the Court granted the motion to withdraw.
Main Doctrine
A petition for certiorari, prohibition, and mandamus, seeking to annul an administrative order of suspension and the designation of an acting mayor, becomes moot and academic when the petitioner is re-elected to his position and the respondents cease to hold their respective offices, rendering any resolution of the case without practical purpose.