Lewis v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute involved a case of unlawful detainer filed by Zamboanga Commercial & Trading Corporation against Spouses Diosdado and Araceli Lewis. The City Court of Zamboanga ruled against the Spouses Lewis, a decision which was subsequently appealed. 2. Procedural History: The Spouses Lewis appealed the City Court's decision to the Court of First Instance (CFI) of Zamboanga City. The CFI, presided over by Judge Abdulwahid A. Bidin, dismissed the appeal, thereby upholding the City Court's ruling. The Spouses Lewis then appealed this dismissal to the Court of Appeals, which also affirmed the lower courts' decisions. This petition for review on certiorari to the Supreme Court followed. 3. The Petition: The Spouses Lewis filed a petition for review on certiorari, seeking to overturn the decision of the Court of Appeals. They argued that the Court of Appeals committed grave and reversible errors of law. However, the Supreme Court noted that the CFI had already decided the appeal on the merits, dismissing the Spouses Lewis's appeal and sustaining the City Court's decision. Furthermore, the Supreme Court observed that the judgment below had become final and executory, rendering the petition moot and academic. The Court also considered the private respondent's motion to dismiss based on the mootness of the case.
Issue(s)
Whether the petition for review on certiorari has become moot and academic. Whether the Court of Appeals erred in sustaining the writ of execution issued by the respondent judge.
Ruling
The Supreme Court granted the respondent's Motion to Dismiss and dismissed the case at bar.
Ratio Decidendi
On the issue of the petition being moot and academic: The Court found that the petition had become moot and academic. This was primarily due to the fact that the respondent Presiding Judge of the Court of First Instance had already decided the appeal in the original detainer case by dismissing the petitioners' appeal and affirming the City Court's decision. Furthermore, the petitioners' counsel received the decision on March 20, 1978, and only filed a late Motion for Reconsideration on April 20, 1978, which was denied on June 9, 1978, for lack of merit. The denial explicitly stated that the decision sought to be reconsidered had become final and executory. The receipt of the denial on June 14, 1978, further solidified the finality of the judgment. On the issue of the Court of Appeals' alleged error in sustaining the writ of execution: The Court reviewed the allegations, issues, and arguments presented in the petition for review on certiorari. In light of the pleadings and the record, the Court found no substantial grounds to attribute "grave and reversible errors of law" to the respondent Court of Appeals. The appellate court had sustained the writ of execution issued by the respondent judge. This action was based on the petitioners' failure to file a sufficient supersedeas bond. At any rate, the judgment below had, by this time, become final and executory, rendering the issue at bar moot. The Court cited Sollorano vs. Court of Appeals and a Resolution dated August 3, 1977, in De Ocampo vs. Court of Appeals as supporting its stance.
Main Doctrine
A petition for review on certiorari will be dismissed if it has become moot and academic due to the final and executory nature of the judgment sought to be reviewed, especially when no substantial grounds exist to attribute grave and reversible errors to the appellate court.