Parojinog v. Marave
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the position of Deputy Chief of Police of Ozamis City. Petitioner Pedro C. Parojinog, Jr. filed a suit for quo warranto challenging the appointment of respondent Arturo del Pozo to this position. Subsequently, when respondent Timoteo Padilla was appointed to succeed del Pozo, he was also named as a respondent. 2. Procedural History: The quo warranto suit initiated by petitioner Parojinog, Jr. was dismissed by the respondent Judge. The judge's reasoning was that petitioner held a temporary appointment, and his subsequent acquisition of civil service eligibility did not preclude the city mayor from terminating his incumbency. This dismissal led to the current review by certiorari. 3. The Petition: Petitioner seeks review of the dismissal of his quo warranto suit. In a supplemental pleading, petitioner alleged that he was appointed Chief of Police of Ozamis City on January 1, 1972, and continues to hold that office. He also stated that respondent Timoteo Padilla resigned as Deputy Chief of Police on March 15, 1972. Based on these developments, petitioner argued that the issue of entitlement to the Deputy Chief of Police position had become moot and academic.
Issue(s)
Whether the petition for certiorari should be dismissed on the ground that the quo warranto case had become moot and academic.
Ruling
The Supreme Court dismissed the petition for certiorari. The Court held that the case had become moot and academic in light of the petitioner's subsequent appointment as Chief of Police and the resignation of the respondent from the contested position of Deputy Chief of Police.
Ratio Decidendi
On Whether the petition for certiorari should be dismissed on the ground that the quo warranto case had become moot and academic: The Supreme Court found that the petition for certiorari should be dismissed because the underlying quo warranto case had become moot and academic. The Court noted that the petitioner himself, in a supplemental pleading, alleged his appointment as Chief of Police of Ozamis City and the resignation of respondent Timoteo Padilla from the position of Deputy Chief of Police. These supervening events effectively resolved the dispute over who was entitled to the contested position of Deputy Chief of Police. Consequently, there was no longer a practical or legal issue for the Court to decide regarding the original quo warranto petition. The Court reiterated the principle that it will not pass upon issues that have ceased to have any practical effect or legal consequence. Therefore, the petition for certiorari seeking to review the dismissal of the mooted quo warranto case was itself dismissed.
Main Doctrine
The Supreme Court dismissed the petition for certiorari reviewing the dismissal of a quo warranto suit, finding that the case had become moot and academic. The petitioner's subsequent appointment as Chief of Police and the respondent's resignation from the Deputy Chief of Police position rendered the original dispute over entitlement to the latter position irrelevant. This reiterates the principle that courts will not pass upon issues that have ceased to have any practical effect.