Castillo v. Nerez
REITERATIONFacts
The Antecedents: Spouses Agrifino and Concepcion Castillo filed an ejectment complaint against Jaime Nerez for Lot No. 1327 of the Tagum cadastre. Nerez answered the complaint. Procedural History: The case was appealed by Nerez to the Court of First Instance (CFI) of Davao. Nerez filed a motion to dismiss, which the CFI granted, citing lack of cause of action and jurisdiction. The CFI reasoned that there was no demand to vacate and that the Bureau of Lands had jurisdiction due to pending miscellaneous sales applications by Nerez and Porfirio Campos, son of the Castillos, for the disputed lot. The Castillos' motion for reconsideration was denied. The Castillos appealed to the Court of Appeals (CA), which certified the case to the Supreme Court as it involved only a question of law regarding jurisdiction. The Petition: The Supreme Court asked the parties to manifest if the Director of Lands had decided their controversy and if the case had become moot and academic. Nerez stated that the Director of Lands had rendered a decision in his favor, and the administrative case was pending appeal. He prayed for dismissal due to mootness. The Castillos concurred in the prayer for dismissal.
Issue(s)
Whether the lower court correctly dismissed the complaint for lack of cause of action and jurisdiction. Whether the case has become moot and academic.
Ruling
The Supreme Court dismissed the case. No costs.
Ratio Decidendi
On the issue of jurisdiction and cause of action: The Court did not directly rule on the CFI's dismissal for lack of cause of action and jurisdiction. However, the subsequent events and the parties' concurrence in dismissal rendered this procedural issue moot. On the issue of mootness: The Court noted that the Director of Lands had already rendered a decision in favor of Nerez in an administrative case concerning the disputed lot. Although Porfirio Campos appealed this decision to the Secretary of Agriculture and Natural Resources, the pendency of this administrative appeal, coupled with Nerez's manifestation and the Castillos' concurrence, led the Court to conclude that the case had become moot and academic. The Court acknowledged the parties' agreement that the case should be dismissed, thereby obviating the need for further adjudication on the merits of the ejectment suit or the jurisdictional question raised.
Main Doctrine
A case may be dismissed for being moot and academic if an administrative body has already rendered a decision in favor of one party, and the appeal of the other party to a higher administrative body is still pending, especially when both parties concur in the dismissal.