Raquiza v. Equipment Marketing Corporation
REITERATIONFacts
The Antecedents: The underlying dispute concerns a bid for the supply and delivery of 100 units of truck-mounted cranes. The Equipment Marketing Corporation (EMC) sought to be awarded this bid, alleging its offer was the most advantageous to the government. However, the petitioners, the Secretary of Public Works and Communications and the Commissioner of Public Highways, contended that EMC's bid did not comply with the advertised specifications and was not the most advantageous, unlike the bid from Toyo Menka Kaisha, Ltd. Procedural History: EMC filed a complaint on January 15, 1968, with the Court of First Instance of Rizal, seeking to be awarded the bid. On January 17, 1968, the respondent judge issued a restraining order enjoining the petitioners from making or implementing any award to Toyo Menka Kaisha, Ltd. The petitioners, asserting lack of jurisdiction and grave abuse of discretion, filed a petition for certiorari and prohibition with preliminary injunction before this Court. This Court initially issued a resolution requiring respondents to answer and enjoining the respondent judge from enforcing his restraining order. Subsequently, EMC filed another suit in the Court of First Instance of Manila, and the contract for the cranes was executed between Toyo Menka Kaisha, Ltd. and the Bureau of Public Highways. The Petition: The petitioners, the Secretary of Public Works and Communications and the Commissioner of Public Highways, filed a petition for certiorari and prohibition with preliminary injunction. They argued that the respondent judge lacked jurisdiction because the petitioners' offices were located in Manila, not Rizal, and that the judge committed a grave abuse of discretion in issuing the restraining order despite evidence that EMC's bid was non-compliant and not the most advantageous to the government. The petition sought to restrain the enforcement of the lower court's restraining order. Later, the petitioners also argued that the case had become moot and academic due to subsequent events, including the filing of a new suit by EMC in Manila and the actual implementation of the contract with Toyo Menka Kaisha, Ltd.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion amounting to lack of jurisdiction in issuing the restraining order. Whether the petition has become moot and academic.
Ruling
The petition for certiorari and prohibition is dismissed for being moot and academic.
Ratio Decidendi
On the issue of grave abuse of discretion and jurisdiction: The petitioners argued that the respondent Judge lacked jurisdiction because their offices were in Manila, not Rizal, and that he committed a grave abuse of discretion in issuing the restraining order despite evidence that the respondent's bid did not comply with advertised specifications and was not the most advantageous to the government. However, the subsequent events rendered this issue moot. On the issue of mootness: The Supreme Court noted that a contract for the sale of the 100 units of truck-mounted cranes was executed on March 21, 1968, between TMK and the Bureau of Public Highways, and the corresponding letters of credit were opened. Furthermore, EMC itself filed a separate suit for prohibition with preliminary injunction in the Court of First Instance of Manila against the petitioners and TMK, thereby submitting to the jurisdiction of that court and acknowledging the absence of jurisdiction in the respondent court. The Commissioner of Public Highways also confirmed that the purchase had been implemented, all cranes received, and were already in use, rendering the action sought to be enjoined a "fait accompli." Consequently, the case before the Supreme Court, as well as the case before the respondent Judge, had become moot and academic.
Main Doctrine
A petition for certiorari and prohibition will be dismissed for being moot and academic when the subject matter of the controversy has already been implemented and has become a fait accompli, and the parties have subsequently engaged in litigation concerning the same issues in another forum, thereby submitting to its jurisdiction.