Far East Realty Investment, Inc. v. Leuterio
REITERATIONFacts
1. The Antecedents: Far East Realty Investment, Inc. (Far East) initiated an ejectment case against spouses Ang Ka Chui and Virginia Ocson Ang (the Ang spouses) for their failure to pay rentals and vacate premises located at Pasillo B 15-17-19, Republic Supermarket Bldg., Rizal Avenue, Sta. Cruz, Manila. The city court ordered the Ang spouses to vacate and pay back rentals, current monthly rentals, and other charges. 2. Procedural History: The Ang spouses appealed the city court's decision to the Court of First Instance of Manila. After the appeal was perfected, the city court amended its judgment to remove the provision for current monthly rentals. Far East then filed a motion for execution in the Court of First Instance, arguing that the Ang spouses failed to deposit current rentals as per the original judgment. This motion was denied by the lower court, which reasoned that the amended decision did not include payment of current rentals. 3. The Petition: Far East filed a petition for certiorari and mandamus with the Supreme Court, challenging the Court of First Instance's order denying its motion for execution. Far East contended that the lower court improperly gave effect to the city court's amendment, which was made after the city court had lost jurisdiction. Subsequently, both parties informed the Supreme Court that the case had become moot and academic due to the Ang spouses vacating the premises, the finality of a subsequent judgment in favor of Far East which was not executed, the Ang spouses' business becoming inexistent, and the death of Ang Ka Chui.
Issue(s)
Whether the Court of First Instance erred in denying the motion for execution of judgment. Whether the case has become moot and academic.
Ruling
The Supreme Court dismissed the case for having become moot and academic. No costs were awarded.
Ratio Decidendi
On Whether the Court of First Instance erred in denying the motion for execution of judgment: The Court did not directly rule on the merits of the denial of the motion for execution. Instead, it noted that the parties themselves manifested that the case had become moot and academic. This mootness rendered the question of whether the CFI erred in denying the motion for execution irrelevant, as the underlying dispute could no longer be resolved in a meaningful way. The Court's primary concern shifted to the supervening events that had overtaken the original controversy. On Whether the case has become moot and academic: The Supreme Court found that the case had indeed become moot and academic. The Ang spouses had vacated the premises on May 11, 1966. Furthermore, a subsequent judgment in favor of Far East Realty Investment, Inc. dated August 23, 1966, which had become final, was never executed. This was because the business of the defendant spouses had become inexistent, and defendant Ang Ka Chui had died on August 17, 1970. These supervening events rendered the original dispute over the execution of the earlier judgment purely academic, as there was no longer a live controversy to adjudicate.
Main Doctrine
The Supreme Court dismissed the petition for certiorari and mandamus because the case had become moot and academic. This was due to the Ang spouses vacating the premises, the subsequent final judgment in favor of Far East Realty Investment, Inc. which was not executed because the defendant spouses' business became inexistent and one of the defendants died, rendering the original dispute irrelevant.