Espina v. Provincial Board of Southern Leyte
REITERATIONFacts
The Antecedents: Petitioner Edgarino L. Espina was the elected Mayor of Maasin, Southern Leyte from 1967 to December 31, 1971. In January 1969, he was charged with Misconduct in Office in Administrative Cases Nos. 2 and 4 before the Provincial Board of Southern Leyte. He was also charged with Frustrated Murder, for which he was acquitted. Subsequently, he was suspended by the Court of First Instance of Southern Leyte due to a criminal case for Violation of the Anti-Graft and Corrupt Practices Act. Although the Court of Appeals annulled this suspension order, the Government elevated the case to the Supreme Court. On July 14, 1970, the Provincial Board found Mayor Espina guilty of misconduct in office in Administrative Cases Nos. 2 and 4, imposing an aggregate penalty of 17 months suspension, effective until December 31, 1971, the end of his term. Mayor Espina did not appeal this administrative decision. Following the Court of First Instance's suspension order, Vice Mayor Catalino Laraga assumed the office of Mayor, despite the Court of Appeals' annulment of the suspension. Mayor Espina's attempts to reassume office were unsuccessful due to an opinion from the Acting Provincial Fiscal and Resolution No. 1294, Series of 1970, adopted by the Provincial Board, designating the Vice-Mayor as acting mayor during Espina's suspension. Procedural History: The Provincial Board of Southern Leyte found petitioner guilty of misconduct in office and imposed a suspension penalty. Petitioner did not appeal this decision to a higher administrative authority. Petitioner filed an original action for Quo Warranto, certiorari, and Prohibition with Preliminary Injunction with the Supreme Court. The Petition: Petitioner prayed for a writ of preliminary injunction to stop the enforcement of suspension orders and the Vice-Mayor from discharging mayoral functions. He also sought a writ of quo warranto to exclude the Vice-Mayor from the Office of Mayor and to declare himself entitled to it. Furthermore, he asked for the declaration of nullity of the Provincial Board's decision in Administrative Cases Nos. 2 and 4 for lack of jurisdiction or grave abuse of authority, and for the penalties imposed to be declared void. Lastly, he sought a writ of prohibition to permanently restrain the Provincial Board from further proceedings and to make the preliminary injunction permanent.
Issue(s)
Whether the issues raised in the petition for Quo Warranto, certiorari, and Prohibition with Preliminary Injunction have become moot and academic. Whether the Provincial Board of Southern Leyte acted with lack or excess of jurisdiction and/or grave abuse of authority or discretion in rendering its decision in Administrative Cases Nos. 2 and 4.
Ruling
The Supreme Court dismissed the petition for having become moot and academic. It held that no useful purpose would be served by passing on the merits of the petition as any ruling could hardly be of any practical or useful purpose, and no practical relief could be granted. The Court reiterated the settled rule that it will not determine moot questions or abstract propositions.
Ratio Decidendi
On the issue of mootness: The Court found that the resolution of the issues raised in the petition had become moot and academic due to the lapse of time. The petitioner's term of office, which was set to expire on December 31, 1971, had already ended. Furthermore, the respondents, who were the parties to be enjoined, were no longer in office. The Court emphasized that assuming the prayers in the petition were granted, they could no longer be enforced. The Court also noted that the records did not show that the petitioner was elected to public office in the subsequent local elections held on January 18, 1988. Therefore, any ruling on the merits would have no practical or useful purpose. On the jurisdiction and grave abuse of authority: While the petition raised issues concerning the jurisdiction and grave abuse of authority of the Provincial Board, the Court did not delve into these substantive matters. The dismissal of the case on the ground of mootness rendered the discussion of these issues unnecessary. The Court's primary consideration was the practical enforceability of any potential judgment. Since the petitioner's term had expired and the respondents were no longer in office, the relief sought, such as placing the petitioner in possession of the office and enjoining the respondents, could not be granted. The Court cited previous rulings to support its stance that it will not pass upon moot questions or abstract propositions where no practical relief can be afforded.
Main Doctrine
A petition will be dismissed for having become moot and academic when the issues raised can no longer be enforced due to the lapse of time and the parties involved are no longer in office, and no useful purpose would be served by passing on the merits of the case as no practical relief can be granted.