Cabrejas v. Dongallo
REITERATIONFacts
1. The Antecedents: The petitioners, Federico Cabrejas and others, were accused of the crime of arson under Article 322, paragraph 4 of the Revised Penal Code. This offense carries a penalty of prision correccional in its medium and maximum periods, which translates to a duration of 2 years, 4 months, and 1 day to 6 years. 2. Procedural History: The case originated in the Municipal Court of Malaybalay, Bukidnon, presided over by respondent Judge Luis P. Dongallo. Petitioners were charged with arson in Criminal Case No. 1877. Respondent Judge initially denied a motion to try the case on the merits, opting instead for a preliminary investigation, a decision that was later reconsidered. Subsequently, the Provincial Fiscal of Bukidnon refused to present evidence when required by the judge, leading to the dismissal of the arson case by the municipal court. 3. The Petition: The petitioners filed a certiorari and mandamus proceeding with the Supreme Court, assailing the municipal court's orders that denied their motion to have the arson case tried on the merits. They argued that the offense fell within the municipal court's jurisdiction, particularly under Republic Act 3828, which grants enlarged jurisdiction to municipal courts in capital towns for cases with penalties not exceeding prision correccional. They contended that the prosecution should not have the option to determine the venue in cases of concurrent jurisdiction between the municipal court and the Court of First Instance.
Issue(s)
Whether the petition for certiorari and mandamus has become moot and academic due to the dismissal of the underlying arson case. Whether the municipal court of a capital town has jurisdiction to try an arson case on the merits when concurrent jurisdiction exists with the Court of First Instance.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On Whether the petition for certiorari and mandamus has become moot and academic due to the dismissal of the underlying arson case: The Court found that the petition had become moot and academic. This was because the criminal case that was the subject of the petition, Criminal Case No. 1877 for arson, had already been dismissed by the respondent Municipal Court Judge. The dismissal of the underlying case rendered the issues raised in the petition for certiorari and mandamus, which sought to compel the trial of that case on the merits, no longer justiciable. The Court's resolution noted that the order of dismissal was submitted by the petitioners, confirming the supervening event that mooted the controversy. Therefore, there was no longer any practical relief that the Supreme Court could grant. On Whether the municipal court of a capital town has jurisdiction to try an arson case on the merits when concurrent jurisdiction exists with the Court of First Instance: While the Court dismissed the petition on the ground of mootness, the facts presented in the motion to dismiss touched upon the issue of jurisdiction. The petitioners argued that under R.A. 3828, the municipal court of a capital town has enlarged jurisdiction to try criminal cases where the penalty does not exceed prision correccional. The arson case, defined under Article 322, paragraph 4 of the Revised Penal Code, carried a penalty of prision correccional in its medium and maximum periods, which falls within this range. The respondent Judge's initial stance was that due to concurrent jurisdiction with the CFI, his court only had jurisdiction for preliminary investigation. However, he later decided to try the case on the merits, which led to its dismissal when the prosecution refused to present evidence. The resolution of this jurisdictional question was pretermitted by the dismissal of the case.
Main Doctrine
A petition for certiorari and mandamus seeking to compel a court to proceed with a case is rendered moot and academic if the case itself is subsequently dismissed. The Supreme Court will not pass upon issues that have already been resolved by supervening events, as there is no longer any justiciable controversy to resolve. This principle ensures judicial economy and prevents the adjudication of hypothetical or abstract questions.