National Waterworks & Sewerage Authority v. Cloribel
REITERATIONFacts
1. The Antecedents: The underlying dispute involved a contract awarded by the National Waterworks & Sewerage Authority (NAWASA) for the supply and furnishing of pipes. C & C Commercial Corporation challenged this award, leading to legal proceedings. 2. Procedural History: C & C Commercial Corporation filed a case against NAWASA, seeking to restrain NAWASA from implementing the contract. The respondent Judge, Gaudencio Cloribel, issued a restraining order and consolidated the case. NAWASA filed a special action for certiorari and prohibition, alleging procedural irregularities and seeking to nullify the respondent Judge's orders. This Court initially issued a writ of preliminary injunction against the respondent Judge but later modified it to allow the trial on the merits. The case proceeded to trial, and the respondent Judge rendered a decision on October 10, 1967, nullifying the contract and ordering a new public bidding. 3. The Petition: NAWASA initiated this special civil action for certiorari and prohibition, seeking to nullify specific orders of the respondent Judge, including those setting hearings for a preliminary injunction and directing compliance, which NAWASA believed were issued with serious procedural irregularities. NAWASA also sought to lift a restraining order that prevented it from proceeding with a vital program to increase Manila's water supply. However, the subsequent decision on the merits by the respondent Judge rendered this petition moot and academic, as the issues could be resolved in the appeal of that decision (L-28655).
Issue(s)
Whether the special civil action for certiorari and prohibition filed by NAWASA has become moot and academic. Whether the orders issued by the respondent Judge constituted grave abuse of discretion amounting to lack of jurisdiction.
Ruling
The Supreme Court dismissed the special civil action for certiorari and prohibition for being moot and academic. It held that the issues raised by NAWASA could be ventilated in the appeal of the main case, which had already proceeded to trial and a decision on the merits.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the special civil action for certiorari and prohibition had become moot and academic. This was because the main case, Civil Case No. 66679, had already proceeded to trial on the merits after the Supreme Court modified its preliminary injunction to allow such trial. Consequently, the alleged procedural irregularities and the restraining order that formed the basis of the certiorari petition were no longer live issues that needed to be corrected in the extraordinary action. The Court emphasized that it would not pass upon issues that have become moot and academic, as they no longer present a justiciable controversy. The legal issues remaining could be properly disposed of in the appeal of the main case (L-28655). On Issue 2: While the petition alleged grave abuse of discretion, the Court found it unnecessary to pass upon these allegations in the context of the certiorari action because the case had already been decided on the merits. The fact that the respondent Judge rendered a decision on October 10, 1967, declaring the contract null and void and ordering a new public bidding, meant that the proceedings had moved beyond the stage of interlocutory orders that were being challenged. Any errors in the interlocutory orders could be raised and corrected in the appeal of the final judgment. Therefore, the Court found no need to correct the alleged procedural irregularities through a certiorari proceeding that had become moot.
Main Doctrine
A petition for certiorari and prohibition seeking to nullify interlocutory orders and restrain proceedings in a lower court is rendered moot and academic once the main case has proceeded to trial and a decision on the merits has been rendered. The issues raised in the certiorari petition can be ventilated in the appeal of the main case. The Court reiterated that it will not pass upon issues that have become moot and academic.