Lomo v. Mabelin
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the election of a director for the Jimenez-Panaon District of the Misamis Occidental II Cooperative, Inc. (MOELCI II). Petitioner Robinson Lomo and respondent J. Antonio Lim were candidates for this position. The core of the conflict lies in the disqualification of Lomo's candidacy and the subsequent declaration of Lim as the elected director, despite Lomo garnering a majority of the votes cast. 2. Procedural History: MOELCI II's Board of Directors called for an election on February 18, 1984. J. Antonio Lim filed his candidacy on February 3, 1984. Robinson Lomo filed his candidacy on February 13, 1984, but was informed by the Nomination Committee Chairman that his candidacy was disqualified for not meeting the fifteen-day deadline. Despite this, Lomo's candidacy was endorsed by twenty-two members during a general assembly, and he subsequently received more votes than Lim. However, these votes were declared stray, and Lim was proclaimed the winner and confirmed by the Board of Directors. Lomo then filed a petition with the Regional Trial Court (RTC) seeking to enjoin Lim from assuming office and to compel his proclamation. The RTC denied Lomo's application for a preliminary injunction, allowing Lim to take his oath. 3. The Petition: This petition seeks to annul the RTC's order denying the writ of preliminary injunction and to compel the Election Committees to proclaim Robinson Lomo as the duly elected director. Lomo argues that his nomination by at least 15 members was valid under the By-Laws and that he secured a clear majority of the votes cast, thus entitling him to the position. The petition contends that the damage suffered by Lomo due to the respondents' alleged wrongful acts was clearly proven.
Issue(s)
Whether the petition is moot and academic due to supervening events. Whether Robinson Lomo was a duly nominated and elected director for the Jimenez-Panaon District of MOELCI II; specifically, whether his subsequent assumption of the office of Vice-Mayor disqualifies him from serving as a director.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On the issue of mootness due to supervening events: The Supreme Court deemed it unnecessary to pass upon the issues raised because supervening events rendered them moot and academic. Specifically, on April 23, 1986, petitioner Robinson Lomo was designated Vice-Mayor of the Municipality of Jimenez, Misamis Occidental, effective May 1, 1986, and took his oath of office. The Court reiterated the well-settled rule that courts will not determine a moot question or abstract proposition nor express an opinion in a case in which no practical relief can be granted. The case of Bongat vs. Bureau of Labor Relations was cited to support this principle. Consequently, the petition was dismissed. On the issue of Robinson Lomo's qualification as director: Lomo's assumption of office as Vice-Mayor is a supervening event that disqualifies him from serving as a director of MOELCI II. The Court cited Section 3(c) of the Cooperative's By-Laws, which states that no person shall be eligible to remain a Board Member if they hold an elective office in the government above the level of a Barangay Captain. By becoming Vice-Mayor, Lomo is precluded from holding the director position. Therefore, the purpose of the petition, which was to have Lomo installed as director-elect, could no longer be granted.
Main Doctrine
A petition seeking to annul a court order denying a writ of preliminary injunction and to compel proclamation of a candidate is rendered moot and academic by supervening events that disqualify the petitioner from holding the office in question.