Mercader v. Gabas
REITERATIONFacts
The Antecedents: Spouses Eusebio Mercader and Luciana Calumpang filed a complaint for the rescission of their lease contract concerning a sugarcane land with defendant Urbano Gabas. Procedural History: The Court of First Instance of Negros Oriental dismissed the complaint, holding that it lacked jurisdiction over the case because it involved agrarian relations, which fall under the exclusive original jurisdiction of the Court of Agrarian Relations. The Appeal: The spouses Mercader and Calumpang appealed the dismissal order to the Supreme Court.
Issue(s)
Whether the appeal has become moot and academic.
Ruling
The appeal is dismissed for having become moot and academic. No costs.
Ratio Decidendi
On Whether the appeal has become moot and academic: The Supreme Court directed the parties to inform the Court whether the appeal had become moot and academic, considering the possible expiration of the lease contract after the termination of the 1968-69 crop-year. Counsel for both the plaintiffs-appellants and the defendant-appellee manifested that the lease had indeed expired and that the appeal had become moot. Furthermore, counsel for the appellants stated that Eusebio Mercader, one of the appellants, had passed away. Given these confirmations, the Court found that the subject matter of the appeal, the rescission of the lease contract, was no longer extant. Consequently, any resolution by the Court would have no practical effect on the parties' rights or obligations concerning the lease. Therefore, the appeal was dismissed for being moot and academic, with no costs awarded.
Main Doctrine
The Supreme Court dismissed the appeal as moot and academic because the lease contract, which was the subject of the rescission case, had already expired. The Court acknowledged that the parties themselves confirmed the expiration of the lease and the death of one of the appellants, rendering the resolution of the appeal unnecessary and without practical effect.