Bautista v. Municipality of San Jacinto
REITERATIONFacts
The Antecedents: Appellants, engaged as building contractors, were subjected to Municipal Ordinance No. 8, Series 1960, of the Municipality of San Jacinto, Pangasinan. This ordinance imposed a municipal tax of P0.10 per cubic meter of sand and gravel taken from within the municipality's territorial limits. The appellants paid these taxes under protest. Procedural History: The appellants filed an action seeking to annul the ordinance for being unconstitutional and void, alleging various grounds including lack of municipal power to regulate and tax the use of public roads, the municipality not being the owner of the sand and gravel, restriction of freedom of passage, establishment of toll fees, double taxation, and the use of force by police to compel payment. The Court of First Instance of Pangasinan upheld the validity of the ordinance. The case was elevated to the Court of Appeals, which found purely legal issues and elevated it to the Supreme Court. The Petition: The appellants appealed the decision of the Court of First Instance, raising several assignments of error concerning the validity, reasonableness, and constitutionality of Municipal Ordinance No. 8, Series 1960.
Issue(s)
Whether the Municipal Council of San Jacinto and its Mayor were empowered by law to enact Municipal Ordinance No. 8, Series 1960. Whether Municipal Ordinance No. 8, Series 1960, is valid and binding. Whether the municipal license fee of P0.10 per cubic meter of gravel and sand imposed by the ordinance is reasonable, equitable, and just. Whether the assessment of P0.10 per cubic meter constitutes double taxation. Whether the imposition of imprisonment of 30 days and a fine of P100.00 for violation of the ordinance is unconstitutional, unjust, and burdensome. Whether Municipal Ordinance No. 8, Series 1960, is null and void.
Ruling
The appeal is dismissed for being moot and academic.
Ratio Decidendi
On the power of the municipality to enact the ordinance: The Court noted that the issue of whether a municipality has the power to pass such an ordinance has been settled by previous rulings. However, the Court pointed out that the Local Autonomy Act, which governed the case at its incidence, was superseded by the Local Tax Code. Furthermore, Section 64-A of the Local Tax Code explicitly stated that all existing tax ordinances of provinces, cities, municipalities, and barrios were deemed ipso facto nullified on June 30, 1974. Therefore, the issue raised in the appeal had become moot and academic. On the validity and binding effect of the ordinance: Given that the issue of the municipality's power to enact the ordinance had become moot and academic due to subsequent legislation (Local Tax Code), the question of the ordinance's validity and binding effect also became moot. Any declaration on its validity or invalidity would serve no practical purpose. On the reasonableness and justness of the fee: The reasonableness, equity, and justness of the P0.10 per cubic meter fee were rendered moot by the supervening legislation that nullified existing tax ordinances. The Court's pronouncements on these matters would have no practical application. On double taxation: The issue of double taxation was also rendered moot and academic. The Court's determination on whether the ordinance constituted double taxation would not yield any practical relief or serve any useful purpose given the nullification of the ordinance by operation of law. On the penalty for violation: The constitutionality, justice, and burden of the penalty provisions (fine and imprisonment) were similarly mooted. The ordinance itself was deemed nullified, making any discussion on its penalties academic. On the nullity of the ordinance: The Court concluded that the appeal was moot and academic. It cited jurisprudence holding that when no useful purpose would be served by passing on the merits of a case and any ruling would be of no practical or useful purpose, the Court should not determine questions that are moot or abstract, nor express opinions for which no practical relief can be granted. The dismissal for being moot and academic obviated the need for a substantive ruling on the ordinance's validity.
Main Doctrine
A case may be dismissed for being moot and academic if the issues raised have become moot and academic, rendering any ruling thereon of no practical use or value.