Lim v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Certain real properties belonging to petitioner Armando Lim were sought to be expropriated by the Land Tenure Administration, now the Land Authority. The Agrarian Court rendered its decision on January 6, 1964. 2. Procedural History: A motion filed by the Land Authority for extension of time to perfect its appeal was opposed by Lim and denied by the Agrarian Court on the ground that the decision had already become final and executory. The matter was then taken up to the Court of Appeals on a petition for certiorari and mandamus to compel the lower court to give due course to the appeal. The appellate court, in its resolution of June 23, 1964, gave due course to the petition. 3. The Petition: Armando Lim came to this Court on the instant petition for prohibition to stop the Court of Appeals from acting upon the petition for certiorari and mandamus filed therein by the Land Authority. Lim contended that since the amount in controversy in the expropriation case exceeded P200,000.00, an appeal therein fell within the jurisdiction of this Court and not of the Court of Appeals. This contention was subsequently rendered moot by Republic Act No. 5440, which removed the value-in-controversy test for appellate jurisdiction between the Court of Appeals and the Supreme Court in civil cases.
Issue(s)
Whether the Supreme Court has jurisdiction over the appeal in the expropriation case, or if it falls under the appellate jurisdiction of the Court of Appeals. Whether the Court of Appeals has jurisdiction to entertain a petition for certiorari and mandamus to compel the Agrarian Court to give due course to an appeal.
Ruling
The Supreme Court dismissed the petition for prohibition as moot and academic and dissolved the writ of preliminary injunction previously issued. The Court held that the passage of Republic Act No. 5440 rendered the issue moot.
Ratio Decidendi
On Issue 1: The Supreme Court found the petition moot and academic due to the approval of Republic Act No. 5440 on September 9, 1968. This law amended the Judiciary Act of 1948 by removing the value-in-controversy test for determining the appellate jurisdiction between the Supreme Court and the Court of Appeals in civil cases. Therefore, any appeal from the basic expropriation case, if allowed, would now be governed by this new law, making the original dispute over jurisdiction moot. On Issue 2: The Court reasoned that since the appeal from the basic expropriation case, if it were to be taken, would fall under the appellate jurisdiction of the Court of Appeals (as implied by the subsequent legislation and the nature of agrarian cases), the petition for certiorari and mandamus filed with the Court of Appeals to compel the trial court to give due course to such appeal is necessarily within the appellate jurisdiction of the Court of Appeals. The writ of mandamus is considered in aid of the appellate jurisdiction of the higher court.
Main Doctrine
The Supreme Court dismissed the petition for prohibition as moot and academic due to the supervening enactment of Republic Act No. 5440. This new law amended the Judiciary Act of 1948 by removing the value-in-controversy test for allocating appellate jurisdiction between the Supreme Court and the Court of Appeals. Consequently, the issue of whether the appeal in the expropriation case should be lodged with the Supreme Court or the Court of Appeals became moot, as did the ancillary question of whether the Court of Appeals had jurisdiction to issue a writ of certiorari and mandamus to compel the lower court to give due course to the appeal.