Tinio v. Castro
REITERATIONFacts
The Antecedents: Rolando Tinio, a tenant, filed two petitions. In the first petition (G.R. No. 57627), he sought to enjoin the sheriff from executing a judgment of ejectment rendered by the city court of Quezon City. In the second petition (G.R. No. 58966), he prayed for the setting aside of the same judgment. Anna H. Quintal, the landlady and owner of the premises, answered both petitions. Procedural History: The city court of Quezon City rendered a judgment ejecting Rolando Tinio from the premises. Tinio filed two petitions before the Supreme Court seeking to prevent the execution of this judgment. The Petition: Tinio prayed for the enjoining of the sheriff from executing the ejectment judgment and for the setting aside of said judgment.
Issue(s)
Whether the cases have become moot and academic. Whether the petitions should be dismissed.
Ruling
The Supreme Court dismissed the two cases without costs, finding that they had become moot and academic.
Ratio Decidendi
On Whether the cases have become moot and academic: The Court noted that the parties, Rolando Tinio (tenant) and Anna H. Quintal (landlady), filed a joint motion on May 17, 1985. In this motion, they prayed for the dismissal of both cases on the ground that they had become moot and academic. This was because Tinio had already vacated the premises, and possession thereof had been delivered to Anna H. Quintal. The Court acknowledged that supervening events can render a case moot and academic, thereby divesting it of its practical utility and necessity for a judicial determination. The voluntary compliance by the parties with the subject matter of the litigation, or the occurrence of events that make a resolution of the dispute impossible or unnecessary, are common grounds for declaring a case moot and academic. In this instance, the core issue of possession and ejectment was resolved by the tenant's voluntary relinquishment of the premises and the landlady's reacquisition of possession. Therefore, any further adjudication by the Court would serve no practical purpose. On Whether the petitions should be dismissed: Based on the finding that the cases had become moot and academic, the Court proceeded to dismiss both petitions. The dismissal was a consequence of the supervening events that rendered the original dispute between the tenant and the landlady concerning the possession of the premises no longer justiciable. The parties themselves, through their joint motion, indicated their agreement that the legal controversy had ceased to exist. The Court, in its discretion, can dismiss cases that no longer present a live controversy, especially when both parties concur in seeking such dismissal. The dispositive portion of the Resolution explicitly states that the two cases are dismissed without costs, reflecting the Court's action based on the parties' joint prayer and the established mootness of the controversy.
Main Doctrine
Cases that have become moot and academic due to the parties' supervening events, such as the tenant vacating the premises and possession being returned to the landlady, shall be dismissed without costs.