Hiquiana v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Mariano G. Hiquiana was the elected barrio captain of Santol, Quezon City in 1972. In December 1973, Daniel Sakay was appointed barangay captain vice Hiquiana. Hiquiana filed a quo warranto case challenging Sakay's appointment. On May 1, 1974, Sakay obtained an appointment as zone chairman from the President, claiming this superseded Hiquiana's position. Procedural History: Hiquiana filed a quo warranto case (Civil Case No. Q-18398) before the Quezon City Court of First Instance, securing a preliminary injunction on January 31, 1974, enjoining Sakay from discharging his duties and preventing Hiquiana's removal. Hiquiana also filed a motion for contempt against Sakay and Councilor Honorio David. The Department of Local Government and Community Development (DLGCD) was later included as a respondent in the quo warranto case. The Petition: Petitioner Hiquiana filed a petition for certiorari, prohibition, and/or mandamus with preliminary injunction before the Supreme Court, seeking to annul a February 5, 1975 resolution of the Commission on Elections (COMELEC). The COMELEC resolution stated it would recognize the barrio captain officially recognized by the DLGCD for the registration of barangay members for the national referendum on February 27-28, 1975. Hiquiana argued that the President's appointment of Sakay as zone chairman did not render the earlier injunction inefficacious.
Issue(s)
Whether the petition for certiorari, prohibition, and/or mandamus has become moot and academic. Whether the COMELEC resolution dated February 5, 1975, recognizing Daniel Sakay for the referendum registration, was valid.
Ruling
The petition is dismissed as moot and academic. The Court noted that the national referendum for which the COMELEC issued the questioned resolution had already been held, its results tabulated, and announced. Therefore, further consideration of the petition was rendered pointless. However, the Court clarified that this dismissal is without prejudice to the continuation of the hearing of Civil Case No. Q-18398 for quo warranto and the motion for contempt filed by petitioner Hiquiana therein.
Ratio Decidendi
On Issue 1: The Supreme Court dismissed the petition as moot and academic. The Solicitor General pointed out that the reliefs prayed for in the petition pertained to the acts and functions connected with the national referendum scheduled for February 27-28, 1975. This referendum had already been conducted as scheduled, with all barangay members casting their votes, which were subsequently counted, canvassed, and the results announced by the COMELEC on March 15, 1975. Given that the event in question had already concluded, the COMELEC and the Secretary of Local Government and Community Development had nothing further to do with the registration of barangay members for that specific referendum. Therefore, the petition seeking to nullify the COMELEC's resolution concerning that registration had become inconsequential and without practical value. The Court reiterated that a case becomes moot and academic when the events or circumstances that gave rise to the dispute have already transpired or been resolved, rendering further judicial action unnecessary. On Issue 2: While not explicitly ruled upon due to mootness, the COMELEC's resolution was based on recognizing the official appointee of the Department of Local Government and Community Development for the purpose of the referendum registration. The COMELEC faced a situation where both Hiquiana and Sakay were registering members, leading to two separate lists. To resolve this promptly for the referendum, the COMELEC opted to recognize the individual officially recognized by the DLGCD, which was Daniel Sakay. The Court's dismissal of the petition implies that the COMELEC acted within its authority in addressing the immediate need for registration supervision during the referendum, even if the underlying quo warranto case remained pending. The Court's decision to allow the quo warranto case to continue indicates that the resolution of the referendum registration issue by COMELEC did not definitively settle the legality of Sakay's appointment as barangay captain.
Main Doctrine
The Supreme Court dismissed the petition as moot and academic because the national referendum for which the Commission on Elections (COMELEC) issued the questioned resolution had already been conducted, its results tabulated, and announced. Consequently, the issue of who should have supervised the registration of barangay members for that specific referendum had become inconsequential.