Santos v. Bautista
REITERATIONFacts
1. The Antecedents: Petitioners Manuel P. Santos and Ruben P. Bernardo filed a petition for certiorari, prohibition, and mandamus seeking to nullify an order denying their motion for reconsideration and sustaining the respondent judge's jurisdiction to hear a petition for review of a decision and decree of registration in Land Registration Case No. PN-101. The municipal judge of Parañaque had heard the case upon delegation, based on the land's assessed value not exceeding P10,000.00. Respondents, as oppositors in LRC No. PN-101, contended that the municipal judge lacked jurisdiction because the land's value in 1966 was estimated at P750,000.00, exceeding the P10,000.00 threshold for delegated jurisdiction. They also pointed to the pendency of two earlier cases involving the same land: Civil Case No. 617-R (for recovery of possession) and LRC No. PN-96, both before the Court of First Instance of Pasay City. They claimed an agreement to hold LRC No. PN-96 in abeyance pending the outcome of Civil Case No. 617-R and alleged they were not notified of a hearing in LRC No. PN-101. 2. Procedural History: Petitioners filed the instant petition for certiorari, prohibition, and mandamus on April 23, 1971. Respondents filed their answer on June 8, 1971. Both parties later filed their respective memoranda. On October 23, 1972, a joint petition to dismiss was filed by petitioner Manuel P. Santos (assisted by Atty. Angel S. Alvir, not the counsel of record) and all the private respondents. This joint petition stated that all parties had sold their rights to the land to Mariano Z. Velarde. Petitioner Ruben P. Bernardo did not sign this joint petition. His counsel, Attys. Jesus C. Concepcion and Edsel E. Ocson, filed an urgent motion for time to confer with Ruben P. Bernardo. Subsequently, these counsels filed a manifestation detailing related proceedings, including Civil Case No. 12113 (Alano Case) and Civil Case No. 16035 (Santos v. Bernardo Case), and expressing confusion over Atty. Alvir's multiple appearances for different parties. The Supreme Court, in its resolution, noted the sale of rights by Ruben P. Bernardo to Mariano Z. Velarde on February 22, 1972, and by Manuel P. Santos on October 12, 1972, and the agreement of private respondents to sell their rights to Velarde. 3. The Petition: The petition for certiorari, prohibition, and mandamus sought to nullify the respondent judge's order denying the motion for reconsideration and upholding his jurisdiction to hear the petition for review of the decision and decree of registration in LRC No. PN-101. The core issue was whether the municipal judge of Parañaque had jurisdiction to hear LRC No. PN-101, given the assessed value of the land and the pendency of other related cases.
Issue(s)
Whether the Supreme Court should dismiss the petition for certiorari, prohibition, and mandamus as moot and academic. Whether the municipal judge of Parañaque had jurisdiction over Land Registration Case No. PN-101.
Ruling
The Supreme Court dismissed the petition for certiorari, prohibition, and mandamus as moot and academic. The dismissal was without prejudice to the right of Attys. Jesus C. Concepcion and Edsel E. Ocson to institute the appropriate action to protect their interests as counsel for the petitioners.
Ratio Decidendi
On Whether the Supreme Court should dismiss the petition for certiorari, prohibition, and mandamus as moot and academic: The Court dismissed the petition as moot and academic. This was based on the joint petition to dismiss filed by petitioner Manuel P. Santos and all the private respondents. The joint petition averred that all parties involved in the land registration case had subsequently sold, assigned, transferred, and conveyed all their rights, interests, and participations in the subject parcel of land to one Mariano Z. Velarde. Specifically, petitioner Ruben P. Bernardo sold his rights on February 22, 1972, and petitioner Manuel P. Santos conveyed his rights on October 12, 1972. The private respondents also agreed to sell their rights to the same individual. Given these supervening events, any resolution by the Court on the jurisdictional issue would serve no practical purpose, rendering the case moot and academic. The Court explicitly stated that "by virtue of the transfer of all the rights and interests of all the parties in this case to Mariano Z. Velarde, the issues raised by the petition and the answer have become moot and academic as the resolution of which would serve no useful purpose." On Whether the municipal judge of Parañaque had jurisdiction over Land Registration Case No. PN-101: While this was the core issue raised in the original petition, the Supreme Court did not pass upon it directly due to the subsequent mootness of the case. The petition for review of the decision and decree of registration in LRC No. PN-101 was filed before the respondent judge, who denied the motion for reconsideration and sustained his jurisdiction. The petitioners in the present case sought to nullify this order. The respondents argued that the municipal judge lacked jurisdiction because the land's assessed value exceeded P10,000.00, the threshold for delegated jurisdiction under Section 88 of the Judiciary Act. However, because all parties subsequently sold their rights to the same person, Mariano Z. Velarde, the issue of the municipal judge's jurisdiction became moot and academic. The Court's resolution focused on the procedural consequence of the mootness rather than a substantive ruling on jurisdiction.
Main Doctrine
The Supreme Court dismissed the petition for certiorari, prohibition, and mandamus as moot and academic. This was based on the joint petition to dismiss filed by one petitioner and all the private respondents, indicating that all parties involved in the land registration case had subsequently sold their respective rights and interests in the disputed property to a single individual, Mariano Z. Velarde. Consequently, any resolution of the jurisdictional issue raised in the petition would serve no practical purpose.