Sasi v. People
REITERATIONFacts
1. The Antecedents: Petitioner Bienvenido Sasi was convicted of serious physical injuries by the Municipal Court of San Joaquin, Iloilo, and sentenced to an indeterminate sentence. He was also ordered to pay damages and attorney's fees. 2. Procedural History: Following the denial of his application for probation, Sasi filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion by the municipal judge. The Court of Appeals denied his petition. Subsequently, Sasi filed the instant petition with the Supreme Court. 3. The Petition: Sasi seeks reversal of the Court of Appeals' decision and admission to probation. However, the Supreme Court noted a discrepancy in the sentence imposed and received information that Sasi had been granted parole, rendering the petition moot and academic. The Court ordered the Municipal Judge to explain the sentencing discrepancy.
Issue(s)
Whether the petition for certiorari seeking admission to probation has become moot and academic due to the petitioner's subsequent grant of parole. Whether there was a discrepancy in the penalty stated in the decision and the receipt of prisoner regarding the petitioner's sentence.
Ruling
The Supreme Court dismissed the petition for having become moot and academic. However, it ordered the Municipal Judge of San Joaquin, Iloilo, to explain the discrepancy in the penalty stated in the decision and that stated in the receipt of prisoner.
Ratio Decidendi
On Issue 1: The Supreme Court dismissed the petition for certiorari as moot and academic. The Court noted that the petitioner had been granted parole by the Board of Pardons and Parole during the pendency of his petition before the Supreme Court. This supervening event rendered the issue of his admission to probation, which was the subject of the certiorari petition, no longer capable of judicial determination. The Court acknowledged the manifestation of the petitioner's counsel that the issues were rendered moot and academic by the parole. Therefore, the Court found no necessity to pass upon the merits of the petition concerning the denial of probation. On Issue 2: While the petition was dismissed on the ground of mootness, the Supreme Court took notice of a discrepancy in the penalty imposed on the petitioner. The decision stated an indeterminate sentence of two (2) years and four (4) months to six (6) years, while the certified true copy of the Receipt of Prisoner and the Discharge on Parole indicated a sentence of four (4) months and one (1) day to three (3) years, six (6) months, and twenty (20) days. Recognizing this inconsistency, the Court issued a directive to the Municipal Judge of San Joaquin, Iloilo, to provide an explanation for the discrepancy within ten (10) days from receipt of the resolution. This action underscores the Court's commitment to ensuring accuracy and regularity in judicial pronouncements and the execution of sentences.
Main Doctrine
The Supreme Court dismissed the petition for certiorari, which sought to admit the petitioner to probation, on the ground that the case had become moot and academic. This was due to the petitioner having been granted parole by the Board of Pardons and Parole during the pendency of the case before the Supreme Court. The Court emphasized that when events transpire that render the resolution of the issues before it unnecessary or impossible, the case will be dismissed as moot.