Aberin v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners, licensed vendors and stall holders in Quezon City markets, filed a case against Quezon City officials and the proprietors of Nepa-Q-Mart. They alleged that a contract authorizing the operation of Nepa-Q-Mart by the Paculdos was illegally entered into by the city and council, causing a diminution of their earnings. The core of the dispute centered on the validity and legality of this contract and the subsequent operations of the private market. Procedural History: The vendors initiated Civil Case No. Q-8129 in the Court of First Instance (CFI) of Rizal, Quezon City Branch IX, seeking various remedies including certiorari, prohibition, and mandamus. The CFI, presided over by Judge Lourdes P. San Diego, ruled in favor of the vendors, declaring the contract and its authorizing resolutions null and void and ordering the revocation of permits for Nepa-Q-Mart. The vendors then moved for immediate execution of this decision, which the CFI granted. The respondents appealed this order of immediate execution to the Court of Appeals (CA) via a petition for certiorari with preliminary injunction. The Petition: The petitioners-appellants, Quezon City officials and the CFI judge, are seeking review of the Court of Appeals' decision which granted the respondents-appellees' petition for certiorari and set aside the CFI's order for immediate execution. The CA majority found that the case involved questions of fact best left for the main appeal, thus divesting them of immediate jurisdiction. This petition before the Supreme Court challenges that appellate ruling. However, subsequent events, including the demolition of Nepa-Q-Mart due to fire, the reconstruction under a new resolution, and the change in city officials, have rendered the original dispute moot and academic, leading to the dismissal of the case.
Issue(s)
Whether the Court of Appeals erred in setting aside the trial court's order for immediate execution pending appeal. Whether the case has become moot and academic due to supervening events.
Ruling
The Supreme Court dismissed the petition for review on certiorari, holding that the case had become moot and academic due to supervening events. The Court noted that the disputed market was no longer in operation, had been destroyed by fire, and a new market was reconstructed under a different resolution. Furthermore, the public officials who were respondents in the original case were no longer in office, rendering any decision on the validity of the contract or the execution order moot.
Ratio Decidendi
On Issue 1: The Supreme Court dismissed the petition for review on certiorari. The Court took note of the manifestation filed by respondent Paculdo, which included a certification from the City Veterinarian of Quezon City confirming that the Nepa-Q-Mart Slaughterhouse was no longer in operation. Additionally, the market itself had been burned down in a fire in 1972 and subsequently reconstructed under a new City Council Resolution No. 9314 passed in 1973. These supervening events rendered the original dispute regarding the contract's validity and the execution of the trial court's decision moot and academic. Therefore, any ruling on the propriety of the execution order would have no practical effect. On Issue 2: The case was dismissed for having become moot and academic. The Court observed that the respondents in the mother case, who were former city officials, were no longer in office. The acts complained of by the petitioners pertained to the contract authorized and allowed by these former officials. With the change in circumstances, including the cessation of the disputed slaughterhouse's operation and the destruction and reconstruction of the market, there were no longer any acts that could be complained of by the petitioners. Consequently, the case lost its practical utility and was thus dismissed.
Main Doctrine
The Supreme Court dismissed the petition for review on certiorari because the underlying case had become moot and academic due to supervening events. These events included the cessation of the disputed market's operation, the destruction of the market by fire, and the reconstruction under a new resolution, as well as the fact that the public officials involved in the original dispute were no longer in office. Consequently, any ruling on the validity of the contract or the propriety of the execution order would have no practical effect.