Datu v. Pasicolan
REITERATIONFacts
The Antecedents: Petitioners, fishermen of Minalin, Pampanga, were granted annual licenses to fish with 'biacus' nets in specific municipal waters until December 31, 1963, with the right to renew for 1964. The Municipal Council of Minalin enacted Resolution No. 99, series of 1963, withdrawing these waters from petitioners' access and mandating that fishing licenses be granted only to the highest bidder after public auction, with a fixed minimum price. Procedural History: Petitioners filed a complaint with the Court of First Instance (CFI) of Pampanga, praying for a writ of preliminary injunction to stop the public auction scheduled for December 16, 1963, and to compel the issuance of their 1964 fishing licenses at the previous rate. The CFI granted the preliminary injunction upon petitioners' posting of a P1,000.00 bond. Subsequently, respondents moved for the dissolution of the injunction, which the CFI granted through an order dated March 17, 1964, and later approved the P5,000.00 counterbond on April 15, 1964. Petitioners then filed the instant petition for certiorari and prohibition with the Supreme Court seeking to nullify these orders. The Petition: Petitioners filed a petition for certiorari and prohibition seeking to nullify the orders of the CFI of Pampanga that dissolved the writ of preliminary injunction and approved the counterbond. They argued that Municipal Resolution No. 99 was ultra vires and that the public auction should not be held, asserting their right to renewal of their fishing licenses under existing ordinances.
Issue(s)
Whether the Supreme Court should grant the petition for certiorari and prohibition to nullify the orders dissolving the preliminary injunction and approving the counterbond. Whether the case has become moot and academic.
Ruling
The Supreme Court dismissed the petition for certiorari and prohibition, holding that the case is moot and academic. The Court noted that the main prayer in the original case was for the renewal of fishing licenses for the year 1964, which had long expired.
Ratio Decidendi
On Whether the Supreme Court should grant the petition for certiorari and prohibition to nullify the orders dissolving the preliminary injunction and approving the counterbond: The Court found that the petition for certiorari and prohibition had become moot and academic. The underlying dispute in the Civil Case No. 2426 concerned the renewal of fishing licenses for the year 1964. Since the year 1964 had long passed by the time the case reached the Supreme Court, any decision on the validity of the municipal resolution or the propriety of the dissolution of the preliminary injunction would have no practical effect. The Court emphasized that it would not pass upon issues that have lost their practical utility. On Whether the case has become moot and academic: The Court definitively ruled that the case is moot and academic. This conclusion was based on the fact that the subject matter of the original complaint, which was the renewal of fishing licenses for the year 1964, had already expired. The Court also took into consideration the fact that the records of the original Civil Case No. 2426 were sent to the archives due to the parties' failure to set the case for hearing. Furthermore, both counsels for the petitioners and respondents failed to comply with the Court's resolution requiring them to show cause why the case should not be dismissed for failure to prosecute. These circumstances collectively rendered the case moot and academic, warranting its dismissal.
Main Doctrine
The Supreme Court dismissed the petition for certiorari and prohibition, finding the case to be moot and academic. The primary issue revolved around the renewal of fishing licenses for the year 1964, which had long expired by the time the case reached the Supreme Court. Consequently, any ruling on the validity of the municipal resolution or the dissolution of the preliminary injunction would have no practical effect.