Duavit v. Mariano
REITERATIONFacts
The Antecedents: The underlying dispute concerns the authority to suspend or revoke licenses for horse-racing entities. The Philippine Charity Sweepstakes Office (PCSO) and Assistant Executive Secretary Gilberto M. Duavit sought to suspend the license of the Manila Jockey Club, Inc. (MJC) due to alleged undeclared income from charity-sponsored races and the Games and Amusements Board's (GAB) inaction. This suspension led to a directive that races scheduled for MJC should be held at the Philippine Racing Club, Inc. (PRC). Procedural History: The GAB had approved a calendar of races for 1969 for both MJC and PRC. Following the recommendation from the PCSO General Manager and the directive from Assistant Executive Secretary Duavit on June 4, 1969, suspending MJC's license and reassigning its races to PRC, the GAB scheduled a hearing for June 10, 1969, to determine grounds for license revocation. In response, MJC filed a petition for prohibition with preliminary injunction with the Court of First Instance of Rizal (CFI), seeking to restrain the GAB, Duavit, PRC, and other charitable organizations from implementing the directive. The CFI Judge issued a temporary restraining order on June 4, 1969, and later, a preliminary injunction on July 5, 1969, enjoining the implementation of the directive and restraining the petitioners from interfering with the GAB's licensing powers. The Petition: This case is a petition for certiorari and prohibition with preliminary injunction filed by Gilberto M. Duavit and the Philippine Charity Sweepstakes Office. They seek to annul and set aside the orders of the respondent Judge of the CFI of Rizal dated June 6 and July 5, 1969, and to prevent the respondent Judge from further hearing Civil Case No. 11860. The core argument is that the Assistant Executive Secretary, acting on behalf of the Office of the President, possesses the authority to suspend or revoke racing licenses, contrary to the CFI's ruling that only the GAB has such exclusive power. The petitioners contend that the respondent Judge erred in restraining them from implementing the directive and in preventing them from interfering with the GAB's licensing authority.
Issue(s)
Whether the Assistant Executive Secretary has the authority to directly suspend or revoke licenses of racing entities. Whether the respondent Judge correctly issued a writ of preliminary injunction restraining the implementation of the Assistant Executive Secretary's directive and the actions of the petitioners.
Ruling
The Supreme Court granted the petition, set aside the questioned orders of the Court of First Instance of Rizal dated June 6 and July 5, 1969, and made the writ of preliminary injunction permanent. The Court declared the case moot and academic due to supervening events.
Ratio Decidendi
On Issue 1: The Court found that the fundamental issue of whether the Assistant Executive Secretary could directly suspend or revoke licenses of racing entities had become moot and academic. This was due to the enactment of Presidential Decree No. 420, which took effect on March 20, 1974. This decree transferred the functions of the Games and Amusements Board (GAB) concerning horse-racing, except for specific supervisory roles over betting, to the newly created Philippine Racing Commission. The Philippine Racing Commission was vested with exclusive jurisdiction and control over every aspect of horse-racing. Consequently, the respondent Judge could no longer enforce his orders or restrain the petitioners from actions related to the GAB's former powers, as these powers no longer resided with the GAB in the same manner. On Issue 2: The Supreme Court ruled that the respondent Judge could no longer enforce his orders and restrain the petitioners. The issuance of Presidential Decree No. 420, which transferred the functions of the GAB to the Philippine Racing Commission, rendered the dispute over the suspension of the Manila Jockey Club, Inc.'s license and the transfer of races moot. The Court emphasized that the respondent Judge could not validly restrain the petitioners from actions that were now governed by a new legal framework, making the preliminary injunction issued by the CFI ineffective. Therefore, the Supreme Court set aside the questioned orders of the CFI and made the writ of preliminary injunction permanent, effectively nullifying the lower court's actions.
Main Doctrine
The Supreme Court reiterated that a case may be rendered moot and academic by supervening events, such as the transfer of governmental functions, which render the issues no longer justiciable. In this instance, the transfer of the functions of the Games and Amusements Board concerning horse-racing to the Philippine Racing Commission rendered the dispute over the suspension of a license and the authority to conduct races moot, as the respondent judge could no longer enforce his orders.