Flordelis v. Marcial
REITERATIONFacts
1. The Antecedents: Gotardo Flordelis, the administrator of the Bohol School of Arts and Trades, filed a special civil action for prohibition to prevent respondents, including city officials and Ministry of Public Works personnel, from closing the school and inspecting its building to search for incriminating evidence and harass him. 2. Procedural History: The respondents, through the City Fiscal, explained that Flordelis was charged with violating the National Building Code, an inspection team was formed to assess the building's structural stability, and closure orders were issued. 3. The Petition: Flordelis filed a petition for prohibition under Rule 65 of the Rules of Court to restrain the respondents from closing the school and inspecting the building, alleging harassment.
Issue(s)
Whether the petition for prohibition had become moot and academic due to supervening events. Whether the respondents were justified in their actions concerning the inspection and closure of the school building.
Ruling
The Supreme Court dismissed the case and considered it closed, dissolving the temporary restraining order. However, it enjoined the respondents from carrying out a 'seismic test' by ramming the building with a bulldozer without the petitioner's consent.
Ratio Decidendi
On Whether the petition for prohibition had become moot and academic due to supervening events: The Court held that the petition had become moot and academic. The primary purpose of the petition was to prevent the inspection of the school building. During the hearing, the petitioner agreed to allow the inspection in the presence of his representatives. Subsequently, the Solicitor General manifested that the inspection had already been carried out with the petitioner's consent. Therefore, the issue of whether the inspection should be allowed was rendered moot by the subsequent consent and actual inspection, making it unnecessary for the Court to rule on the merits of the prohibition. On Whether the respondents were justified in their actions concerning the inspection and closure of the school building: While the Court dismissed the petition as moot, it did not explicitly rule on the justification of the respondents' actions. However, the comments of the respondents indicated that the inspection was based on concerns about the building's structural stability and potential unwarranted additions, as revealed by Regional Director Benjamin T. Marcial. The City Fiscal also explained the basis for the charges and the issuance of closure orders. The Court, in its resolution, did not delve into the merits of these justifications but focused on the mootness of the prohibition sought.
Main Doctrine
The Supreme Court dismissed the petition for prohibition as it had become moot and academic. The petitioner's initial objective was to prevent the inspection of the school building, but he later agreed to allow the inspection. This supervening event rendered the issue moot, as the action sought to be prohibited had already been undertaken with the petitioner's consent. The Court emphasized that it would not pass upon issues that have already been resolved by circumstances.