Bueno v. Santos
REITERATIONFacts
1. The Antecedents: The underlying dispute involved a sum of money owed by Valeriano C. Bueno to the estate of the late Conrado D. Santos, pursuant to a deed of sale and mortgage. Bueno was ordered by the lower court to deposit P82,257.60. 2. Procedural History: Valeriano C. Bueno appealed the December 4, 1965 order of the Court of First Instance of Rizal to the Court of Appeals. The Court of Appeals, after briefs were filed, certified the case to the Supreme Court on May 8, 1967, deeming it to involve only questions of law. 3. The Petition: The case reached the Supreme Court as an appeal. In a resolution dated June 22, 1977, the parties were asked to address whether the appeal had become moot. Appellant Bueno, in a manifestation dated October 21, 1977, stated the appeal was moot due to his deposit of the P82,257.60 into court on December 9, 1968, which was accepted by the estate's executor, leading to the cancellation of the mortgage.
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 dismissed the appeal on the ground that it had become moot and academic. The appellant, Valeriano C. Bueno, had paid the sum of P82,257.60 to the estate of Conrado D. Santos. This payment was made through a deposit of a check in the Court of First Instance of Rizal at Caloocan City, in connection with other civil cases involving the parties. The executor of the estate was directed by the Caloocan court to accept the check and execute the necessary cancellation of the mortgage. Furthermore, the counsel for the estate confirmed that the payment had been received and that the appeal had indeed become moot. Consequently, there was no longer a live controversy for the Supreme Court to resolve, rendering the appeal academic.
Main Doctrine
An appeal will be dismissed if it has become moot and academic due to supervening events that resolve the core issue of the case. In this instance, the appellant's payment of the amount ordered by the lower court rendered the appeal moot, as there was no longer a live controversy to adjudicate.