Workmen's Insurance Co. v. Alcance

G.R. No. L-35826 · 1973-06-29 · J. FERNANDO, J.: · Primary: Remedial; Secondary: Civil
REITERATION

Facts

1. The Antecedents: The underlying dispute involved a proceeding for mandamus and prohibition initiated by Workmen's Insurance Co., Inc. and Attorney Rafael S. Medina against Arturo Alcance and Avelino Macasaet. 2. Procedural History: The petitioners, Workmen's Insurance Co., Inc. and Attorney Rafael S. Medina, filed a petition for review with the Supreme Court, challenging a decision by the Court of Appeals that had dismissed their prior proceeding for mandamus and prohibition. The Court of Appeals' decision was alleged to have failed to consider circumstances that could have led to an arbitrary actuation. 3. The Petition: The petition for review was filed under Rule 45 of the Rules of Court. The petitioners argued that the Court of Appeals' decision was erroneous due to its failure to account for specific circumstances. However, subsequent manifestations from both petitioners and respondents indicated that the parties had reached an extra-judicial settlement, rendering the case moot. The respondents had advanced P10,000.00, with the balance paid in full, leading to a joint request for dismissal.

Issue(s)

Whether the petition for review should be dismissed considering the extra-judicial settlement between the parties. Whether the case has become moot and academic due to the settlement.

Ruling

The Supreme Court dismissed the petition. It noted that both parties agreed that the case had become moot and academic due to an extra-judicial settlement and that the petition should be considered withdrawn.

Ratio Decidendi

On Issue 1: The Supreme Court dismissed the petition because both parties, the petitioners and the private respondents, manifested their agreement that the case had become moot and academic. This agreement stemmed from an extra-judicial settlement they had entered into to resolve the underlying dispute. Consequently, the Court found no further justiciable controversy to resolve. On Issue 2: The Court found the case to be moot and academic based on the manifestations of both parties. The private respondents filed a manifestation stating that the parties had agreed to settle the case extra-judicially, with private respondents having already advanced P10,000.00 and the balance payable soon. Petitioners subsequently filed their own manifestation, agreeing that the petition was moot due to the settlement and that the balance had been paid in full. This supervening event rendered the petition for review unnecessary.

Main Doctrine

The Supreme Court dismissed the petition for review, finding that the case had become moot and academic due to an extra-judicial settlement between the petitioners and private respondents. The parties had agreed to settle the dispute, with partial payment already made and the balance to be paid. This supervening event rendered the original petition for mandamus and prohibition unnecessary, leading to its withdrawal and dismissal by the Court.

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