Bautista v. Navarro
REITERATIONFacts
The Antecedents: Petitioner, Judge Atilano C. Bautista of the Municipal Court of Montalban, Rizal, was permanently enjoined by respondent Judge Pedro C. Navarro of the Court of First Instance of Rizal from proceeding with the preliminary investigation of Criminal Case No. 1303, People of the Philippines v. Maximo Calalang. Procedural History: Petitioner filed a petition for certiorari before the Supreme Court, arguing that respondent Judge committed a grave abuse of discretion by enjoining the preliminary investigation, citing the doctrines in Dasalla v. City Attorney and Isip v. Gonzales, which held that a motion to suspend proceedings on the ground of a prejudicial question should be raised after the filing of an information, not during the preliminary investigation. The Petition: Petitioner sought to have the decision of respondent Judge Navarro set aside and the case dismissed, contending that the issue had become moot and academic.
Issue(s)
Whether respondent Judge committed a grave abuse of discretion in enjoining the preliminary investigation. Whether the petition has become moot and academic.
Ruling
The appeal by way of certiorari against respondent Judge is ordered dismissed for being moot and academic.
Ratio Decidendi
On the issue of grave abuse of discretion: The petitioner contended that the respondent Judge committed a grave abuse of discretion by enjoining the preliminary investigation, contrary to established jurisprudence. The petitioner cited Dasalla v. City Attorney and Isip v. Gonzales, which held that a motion to suspend proceedings due to a prejudicial question should be raised after the filing of an information, not during the preliminary investigation stage. The petitioner argued that the respondent Judge's action disregarded these doctrines. However, the subsequent events rendered this issue moot. On the issue of mootness: The Supreme Court noted that a manifestation and motion for clarification was filed by the petitioner, stating that the complainant had withdrawn the charge against private respondent Maximo Calalang in Criminal Case No. 1303. This withdrawal was based on an amicable settlement of their differences, evidenced by a joint motion to dismiss. Consequently, the Court observed that no further action was needed as the controversy had been settled by the parties. The dismissal of the criminal case directly impacted the preliminary investigation, rendering the original issue of the injunction moot and academic. The Court acknowledged the order from the Court of First Instance dismissing the special civil case due to the withdrawal of the criminal complaint, confirming the settlement of the dispute.
Main Doctrine
A petition for certiorari seeking to annul a lower court's injunction against a preliminary investigation becomes moot and academic when the criminal case that precipitated the investigation is dismissed due to an amicable settlement between the parties.