Hi Cement Corp. v. Price Control Council
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the legality and constitutionality of a controlled price set by the Price Control Council for cement. HI Cement Corporation, the petitioner, argued that this controlled price was established and extended without affording manufacturers an opportunity to be heard, thus violating procedural due process and the provisions of Republic Act No. 6124. 2. Procedural History: The petitioner filed a petition for prohibition on September 22, 1971, challenging the Price Control Council's controlled price for cement and the constitutionality of the Price Control Act (Rep. Act No. 6361). The Supreme Court required respondents to file an answer, which was submitted on March 16, 1972. Subsequently, on April 6, 1972, the petitioner filed a manifestation indicating a change in the factual basis of the case due to a new controlled price being set. 3. The Petition: The petition, filed under Rule 45, raised several grounds, including violations of procedural due process, equal protection, and substantial due process due to an alleged oppressive and confiscatory price. The petitioner argued that the controlled price was set without a hearing, that the retrospective provision of Rep. Act No. 6361 was unconstitutional, and that the composition of the new Price Control Council was discriminatory. However, the petitioner later manifested that it was no longer interested in pursuing the petition due to a new controlled price being set, opting to seek remedies elsewhere.
Issue(s)
Whether the petition for prohibition should be dismissed based on the petitioner's manifestation that the factual basis of the legal challenge has changed and that it no longer intends to pursue the case.
Ruling
The petition is dismissed without pronouncement as to costs.
Ratio Decidendi
On Issue 1: The Supreme Court (SC) found that the petitioner's own manifestation acknowledged a radical change in the factual circumstances of the case. By setting a new price of P4.75 per bag, the Price Control Council (PCC) superseded the P4.30 price order that was the primary target of the petition for prohibition. The Petitioner explicitly stated that this subsequent action by the PCC 'removed the basis of petitioner's legal contention' in the current case. Applying the principle of judicial economy and acknowledging the petitioner's right to withdraw, the Court accepted the manifestation that the Petitioner was no longer interested in pursuing the petition. The Court noted that the Petitioner intended to seek remedies in other fields of legal action, specifically before the PCC itself. Therefore, the Court determined that the dismissal of the petition was appropriate as there was no longer a live controversy for the Court to resolve based on the original pleadings. This dismissal follows the standard practice of the Court when a petitioner voluntarily abandons its prayer for relief due to a shift in administrative policy or factual landscape.
Main Doctrine
The Supreme Court dismissed the petition for prohibition as moot and academic because the petitioner, Hi Cement Corporation, manifested that it was no longer interested in pursuing the case due to the Price Control Council setting a new controlled price for cement. This supervening event rendered the original issues concerning the validity and enforceability of the previous controlled price moot, as the petitioner indicated it would pursue remedies before the Price Control Council itself.