Balindong v. Mandangan
REITERATIONFacts
The Antecedents: The underlying dispute involved a challenge to the validity of a preventive suspension order issued against Amer M. Balindong, the then Mayor of Balabagan, Lanao del Sur. The suspension was based on two complaints filed against him: one for oppression and misconduct in office, and another for dishonesty and misconduct in office. Procedural History: Amer M. Balindong initiated this certiorari and prohibition proceeding to contest the preventive suspension order issued by the Provincial Governor, Vice-Governor, and Members of the Provincial Board of Lanao del Sur. This Court issued a resolution on May 30, 1969, requiring the respondents to answer and simultaneously issued a writ of preliminary injunction against the enforcement of the suspension order. Respondents filed an answer and sought to lift the injunction, but their plea was not granted. Subsequent pleadings and memoranda were filed by both parties. The Petition: The petitioner sought a writ of certiorari and prohibition to nullify the preventive suspension order. However, by the time the case reached its later stages, it was admitted by the respondents that the case would become moot and academic by December 31, 1971. Given the passage of time, the 1971 elections, and the adoption of the 1973 Constitution, which also introduced changes to provincial boards via Presidential Decrees, the Court found that the issues raised were no longer consequential and dismissed the petition as moot and academic.
Issue(s)
Whether the petition has become moot and academic.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On Whether the petition has become moot and academic: The Court found that a significant amount of time had passed since the filing of the petition, including regular elections for provincial and municipal officials in 1971 and the adoption of the 1973 Constitution. It was evident that the issues raised by the petitioner would serve no purpose or consequence. Furthermore, there was no showing that the parties had retained their previous positions. The Court also noted that Presidential Decrees had introduced changes not only in the names but also in the membership of provincial boards, further altering the circumstances. Consequently, the case was dismissed for being moot and academic, as any ruling would be purely academic and without practical effect.
Main Doctrine
The Supreme Court will dismiss a petition if the issues raised have become moot and academic due to the passage of time, subsequent elections, or changes in the governing laws and structures, rendering any decision purely academic and without practical consequence.