Sayco v. Philippine Sugar Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute involved sugarcane planters who challenged the authority of the Philippine Sugar Commission (PHILSUCOM) and its trading arm, the National Sugar Trading Corporation (NASUTRA). The planters contended that PHILSUCOM's powers to act as the sole buying and selling agency for sugar and to set floor-ceiling prices were oppressive and violated their constitutional rights, specifically raising a due process question regarding the application of Presidential Decree No. 388, as amended. 2. Procedural History: The case originated as a special civil action for prohibition filed by the petitioner-planters against PHILSUCOM and NASUTRA. The Supreme Court initially issued a resolution on December 3, 1982, dismissing the petition. Subsequently, the petitioners filed a motion for reconsideration, arguing that PHILSUCOM's actions, particularly the issuance of warehouse receipts in its name for the planters' sugar, were ultra vires and constituted a deprivation of property without due process. However, before this motion could be resolved, Presidential Decree No. 1791 was issued. 3. The Petition: The petitioners, representing themselves and other sugarcane planters, filed a special civil action for prohibition. Their primary contention was not the unconstitutionality of Presidential Decree No. 388 itself, but its alleged unconstitutional application, which they believed resulted in oppressive actions by PHILSUCOM and NASUTRA. Following the initial dismissal, their motion for reconsideration focused on the ultra vires nature of PHILSUCOM's directive to sugar mills to issue warehouse receipts in PHILSUCOM's name, arguing this action exceeded the authority granted by the decree and deprived them of property without due process. The subsequent issuance of Presidential Decree No. 1791 rendered the case moot and academic.
Issue(s)
Whether the powers of PHILSUCOM and NASUTRA under Presidential Decree No. 388, as amended, are oppressive and violative of petitioners' constitutional rights. Whether the transfer of ownership of sugar to PHILSUCOM through the issuance of warehouse receipts in its name, without explicit authority from Presidential Decree No. 388, constitutes an ultra vires act and a deprivation of property without due process.
Ruling
The Supreme Court denied the motion for reconsideration and dismissed the petition, holding that the case had become moot and academic due to the issuance of Presidential Decree No. 1791.
Ratio Decidendi
On the issue of whether the powers of PHILSUCOM and NASUTRA under Presidential Decree No. 388, as amended, are oppressive and violative of petitioners' constitutional rights: The Court noted that the sugar industry is affected with public interest, making police power measures generally sustainable unless shown to be arbitrary or oppressive. The respondents argued that NASUTRA, in fact, paid producers an amount no lower than the cost of production plus a fair return on investment, even when market prices were low. They also implemented a protective pricing policy for export sugar, selling 50% at a minimum price to ensure certainty and protect against drastic falls. The Court took judicial notice of the severe crisis in the sugar industry and the fact that Philippine sugar was being sold at significantly higher prices due to existing contracts. The Court also suggested that complaints regarding the allocation of prices could be addressed in an administrative forum or through an appeal to the President. Ultimately, the Court found no showing of arbitrariness or oppression, and thus no valid cause for complaint or unconstitutional application. On the issue of whether the transfer of ownership of sugar to PHILSUCOM through the issuance of warehouse receipts in its name, without explicit authority from Presidential Decree No. 388, constitutes an ultra vires act and a deprivation of property without due process: The Court found it unnecessary to resolve this issue. The motion for reconsideration was filed after Presidential Decree No. 1791 was issued on February 21, 1985. Section 6 of this new decree mandated the conversion of NASUTRA into a private corporation, to be called the Philippine Sugar Marketing Corporation (PHILSUMA), which would be owned 100% by sugar producers and would serve as the sole marketing agency for the sugar industry. Given this subsequent legislation and its implementation, the suit against the former PHILSUCOM and NASUTRA had become moot and academic. The Court's resolution in Ledesma v. Philippine Sugar Commission was also cited as precedent for cases rendered moot by subsequent legislative changes.
Main Doctrine
A case becomes moot and academic when subsequent legislation or events render the issues raised therein no longer tenable or resolvable.