Papilota v. Court of Appeals
REITERATIONFacts
1. The Antecedents: On June 30, 1969, a collision occurred between a passenger jeepney and two Coca-Cola trucks owned by San Miguel Corporation (SMC), driven by Romeo C. Zarris. This incident resulted in the deaths of Crispulo Papilota and Warlito Calmerin, and injuries to several other passengers. In a subsequent criminal case, Zarris was acquitted. However, in a civil case filed by the victims' families and injured parties against Zarris and SMC, the court ordered them to pay P433,000.00 in damages and attorney's fees. 2. Procedural History: Following the civil judgment, SMC and Zarris filed a notice of appeal and paid the appeal bond, being granted time to file their record on appeal. They also filed a motion for reconsideration and/or new trial. The petitioners sought execution of the judgment, arguing that the appeal and motion for new trial were improperly filed. The trial judge denied the motion for reconsideration, disallowed the appeal, and ordered the issuance of a writ of execution, leading to the attachment and auction of SMC's trucks. SMC and Zarris then filed a petition for certiorari and mandamus with preliminary injunction with the Court of Appeals, which issued a writ of preliminary injunction enjoining the enforcement of the trial court's orders. The petitioners' motion to lift this injunction was denied, prompting the present petition. 3. The Petition: The petitioners filed a petition for certiorari and prohibition with preliminary injunction, seeking to restrain the enforcement of the Court of Appeals' preliminary injunction and to prohibit the Court of Appeals from further cognizance of the case. They questioned the appellate jurisdiction of the Court of Appeals. However, subsequent resolutions by the Supreme Court in a related case (G.R. No. L-46693), which reviewed the Court of Appeals' decision in CA-G.R. No. SP-06239, denied the petition for review on certiorari for lack of merit. The Supreme Court found that these resolutions rendered the issue of jurisdiction in the present petition moot and academic, effectively affirming the Court of Appeals' decision to give due course to SMC and Zarris' appeal.
Issue(s)
Whether the Court of Appeals had appellate jurisdiction over the petition for certiorari and mandamus filed by San Miguel Corporation and Romeo Zarris, or if the case has been rendered moot and academic.
Ruling
The petition is dismissed for being moot and academic, and also for lack of merit, without pronouncement as to costs.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the present petition is moot and academic due to the finality of the resolutions in the related case, G.R. No. L-46693. The Court observed that its previous denial of the petitioners' petition for review for 'lack of merit' was a recognition of the Court of Appeals' (CA) jurisdiction to entertain the private respondents' petition for mandamus and certiorari. Applying the ruling in Tayag v. Yuseco, the Court clarified that a denial for lack of merit is in effect an affirmation that the challenged decision is correct. Since the CA's decision to give due course to the respondents' appeal was upheld with finality, there is no longer a justiciable controversy regarding the CA's jurisdiction to issue a preliminary injunction. The Court reiterated that it does not countenance further discussion on issues where the entire core of the petition has been firmly set by prior resolutions. Consistent with Meralco Workers Union v. Yatco, the Court refused to decide purely academic questions that would have no practical legal effect.
Main Doctrine
A petition for certiorari and prohibition is rendered moot and academic when this Court has already denied, for lack of merit, a petition for review on certiorari of the decision of the Court of Appeals that was the subject of the original petition.