Carisma v. Divinagracia
REITERATIONFacts
1. The Antecedents: This case originated from a dispute over the position of municipal treasurer of Victorias, Negros Occidental. On July 31, 1967, Calixto Carisma, the acting provincial treasurer, designated Romulo Mercado, then municipal treasurer of Kabankalan, to the vacant position of municipal treasurer of Victorias. Procopio Disen and Eduardo Mahilum, who were the municipal treasurers of Sagay and Toboso respectively, also sought this promotion due to its higher rank and salary. They formally protested Mercado's designation through various administrative channels and subsequently filed a mandamus action. 2. Procedural History: Disen and Mahilum initiated a mandamus action in the Court of First Instance of Negros Occidental (Civil Case No. 530) to compel the provincial treasurer to appoint one of them to the vacant position. The provincial treasurer filed a motion to dismiss this mandamus case, arguing that the petitioners had not exhausted their administrative remedies. The lower court denied this motion. In response to this denial, Carisma and Mercado filed the instant certiorari and prohibition case in the Supreme Court to annul the lower court's order. 3. The Petition: Carisma and Mercado filed a petition for certiorari and prohibition with the Supreme Court, seeking to annul the order of the Court of First Instance of Negros Occidental that denied their motion to dismiss the mandamus case filed by Disen and Mahilum. The Supreme Court granted due course to the petition and issued a temporary restraining order. However, during the pendency of the case, it was determined that the matter had become moot and academic due to significant changes in the positions and status of the parties involved, including Mercado's subsequent appointments and the deaths or retirements of Disen and Mahilum.
Issue(s)
Whether the case has become moot and academic. Whether the lower court erred in denying the motion to dismiss the mandamus case on the ground of failure to exhaust administrative remedies.
Ruling
The Supreme Court dismissed the case for having become moot and academic. No costs were awarded.
Ratio Decidendi
On Whether the case has become moot and academic: The Court found that the case had indeed become moot and academic. This conclusion was based on the manifestations of the parties. The provincial fiscal, representing the petitioners, stated that Mercado was no longer the acting municipal treasurer of Victorias, having been appointed city treasurer of Bago City and later of Cadiz City. Furthermore, Rodrigo Locsin was the incumbent municipal treasurer of Victorias. The respondent Disen had passed away, and his co-respondent Mahilum had retired from the service after becoming municipal treasurer of Sagay. Petitioner Mercado also confirmed that he was appointed permanent municipal treasurer of Victorias on December 12, 1967, and is now the city Treasurer of Cadiz City. Given these supervening events, the original dispute regarding the designation of the municipal treasurer of Victorias was rendered irrelevant, and any decision by the Court would be purely academic. On Whether the lower court erred in denying the motion to dismiss the mandamus case on the ground of failure to exhaust administrative remedies: While this was the core issue presented in the petition for certiorari and prohibition, the Court did not directly rule on it because it dismissed the case on the ground of mootness. The denial of the motion to dismiss by the lower court was the subject of the certiorari petition. However, since the underlying dispute that led to the mandamus case and subsequently to the certiorari case had been resolved by subsequent events, the necessity of passing upon the procedural issue of exhaustion of administrative remedies was obviated. The Court's primary concern became the resolution of the case based on its current status, which was moot.
Main Doctrine
The Supreme Court dismissed the case for having become moot and academic. This was based on the manifestation of the parties that the issues concerning the designation of the municipal treasurer of Victorias, Negros Occidental, were no longer tenable due to subsequent appointments and retirements of the individuals involved, rendering any decision on the matter purely academic.