Filoil Refinery Corporation v. Sayo
REITERATIONFacts
1. The Antecedents: Private respondents, as lessors, initiated an ejectment case against petitioner Filoil Refinery Corporation. The City Court of Caloocan City, whose decision was affirmed by the Court of First Instance of Rizal, Branch XXXIII, ordered Filoil and all those claiming rights under it to vacate the leased premises and pay P24,000.00. 2. Procedural History: Filoil Refinery Corporation appealed the decision of the Court of First Instance to the Court of Appeals. Recognizing that the sole issue involved the interpretation of the lease agreement, a legal question, the Court of Appeals certified the case to the Supreme Court on May 10, 1977. The case was subsequently docketed in the Supreme Court on June 3, 1977. 3. The Petition: The case reached the Supreme Court on a petition for review. However, private respondents subsequently filed a motion to dismiss, arguing the petition was moot and academic because the 20-year lease period expired on June 15, 1980. Filoil admitted the expiration but contended that its sub-lessee, Security Development and Realty Corporation, remained in possession, necessitating a separate ejectment case against the sub-lessee. The Supreme Court found that any sub-lessee or claimant under Filoil could not remain in possession beyond the lease expiry date.
Issue(s)
Whether the ejectment case has become moot and academic due to the expiration of the lease agreement during the pendency of the petition before the Supreme Court.
Ruling
The Supreme Court dismissed the petition as moot and academic. It directed petitioner Filoil Refinery Corporation and all others claiming any right under it, including its sub-lessee Security Development and Realty Corporation, to vacate the premises subject matter of the lease contract dated March 15, 1960. The resolution was made immediately executory.
Ratio Decidendi
On Whether the ejectment case has become moot and academic due to the expiration of the lease agreement during the pendency of the petition before the Supreme Court: The Supreme Court held that the case had indeed become moot and academic. It noted that there was no dispute that the lease contract had expired on June 15, 1980. The Court emphasized that any sub-lessee of Filoil or any other person or entity claiming any right under the petitioner could not remain in possession of the property beyond the expiry date of the lease contract. Therefore, the petition for review was dismissed as the issue of possession based on the expired lease was no longer justiciable. The Court further directed Filoil and all those claiming rights under it, including its sub-lessee, to vacate the premises, making the resolution immediately executory.
Main Doctrine
The Supreme Court reiterated that a case becomes moot and academic when the subject matter of the dispute has already been resolved or has ceased to exist. In this instance, the expiration of the 20-year lease agreement rendered the ejectment case moot and academic, as the petitioner's right to possess the premises had terminated by operation of law. Consequently, the Court dismissed the petition and directed the petitioner, along with any sub-lessees or other occupants claiming rights under it, to vacate the premises.