Guison v. Chief of the Philippine Constabulary
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the legality of cockfighting operations at the La Lorna Cockpit in Quezon City. Petitioners, heirs of Narciso Guison, sought to operate their cockpit on Saturdays and certain weekdays under permits issued by the Quezon City Mayor, pursuant to local ordinances. However, the Chief of the Philippine Constabulary and the PC Provincial Commander of Rizal repeatedly intervened, ordering the cessation of these operations and threatening closure, asserting that such activities were illegal. 2. Procedural History: The petitioners initially filed an action for declaratory relief (Spec. Civil Action No. 6446) after the Chief of the Criminal Investigation Service ordered them to stop Saturday cockfighting, which was declared illegal by the Court of First Instance. Subsequently, after the Quezon City Council enacted Ordinance No. 64-5990, authorizing weekday cockfighting, the petitioners were again obstructed by the PC Provincial Commander. This led to a petition for injunction (Civil Case No. Q-8645) filed with the Court of First Instance of Rizal, Quezon City Branch. The trial court denied the respondents' motion to dismiss but later denied the petitioners' petition for injunction, lifting the preliminary injunction. The petitioners appealed this decision to the Supreme Court. 3. The Petition: The petitioners appealed to the Supreme Court, arguing that the respondents lacked police authority in Quezon City and the standing to question Quezon City Ordinance No. 64-5990. They also contended that the prior judgment in Civil Case No. 6446 was not a bar to their current proceedings and that they had a valid cause of action. The appeal was filed under the premise of reviewing questions of law. However, the Supreme Court noted that subsequent events, including the declaration of martial law and the enactment of Presidential Decrees integrating police forces and regulating cockfighting, rendered the issues moot and academic. The Court also affirmed the trial court's finding that the ordinance authorizing weekday cockfighting was invalid, citing previous jurisprudence.
Issue(s)
Whether the respondents have police authority in Quezon City. Whether the respondents have the personality or are the real parties in interest to question Quezon City Ordinance No. 64-5990. Whether the judgment in Civil Case No. 6446 was a bar to the instant proceedings. Whether the petitioners have a cause of action.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, holding that the issues raised by the appellants have become moot and academic due to subsequent events and legislation, rendering the appeal without merit.
Ratio Decidendi
On the issue of mootness: The Court noted that subsequent to the rendition of the judgment below, Presidential Decree No. 1081 placed the country under martial law, and Presidential Decree Nos. 421, 482, 531, 641, and 765 integrated police forces under the administrative supervision of the Chief of the Philippine Constabulary. Furthermore, Presidential Decree No. 449, the Cockfighting Law of 1974, granted the Chief of the Philippine Constabulary authority to supervise cockfights and cockpit operations. These developments rendered the issues concerning the authority of the PC and the validity of the local ordinance moot and academic. On the validity of the ordinance and cause of action: The Court reiterated its ruling in Quimsing v. Lachica and Chief of the Philippine Constabulary v. Sabungan Bagong Silang, Inc., et al., which held that an ordinance authorizing cockfighting at the discretion of the municipal mayor on days other than those authorized by law is null and void. Since the permit for weekday cockfighting was issued pursuant to Ordinance No. 64-5990, which was deemed invalid, the petitioners had no cause of action. On the respondents' authority and personality to question the ordinance: While the appellants argued that police authority was vested exclusively in the City Mayor and that respondents lacked personality to question the ordinance, the Court found these issues moot due to the supervening events and subsequent legislation that placed PC authority over cockfighting operations. The Court did not directly rule on these specific assignments of error but rather dismissed the appeal on the ground of mootness. On the prior judgment as a bar: The Court implicitly affirmed the trial court's finding that the prior judgment declaring Ordinance No. 60-4346 null and void was relevant to the present case, particularly in establishing the invalidity of ordinances that were ultra vires. However, the primary basis for dismissing the appeal was the mootness of the issues.
Main Doctrine
An appeal raising issues that have become moot and academic due to subsequent legislation or supervening events will be dismissed.