Avedana v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership and possession of a residential lot located at 316 G-Villanueva St., Pasay City. Manuel Bautista, the original owner, leased a portion of this lot to petitioners Leonarda Avedana and Purificacion Timbang, on which they constructed a house. Following Manuel Bautista's death, his children executed deeds that, through a series of transfers, ultimately resulted in private respondent Manolito Bautista claiming ownership of the entire property. Manolito Bautista then filed a complaint to eject the petitioners from the leased premises. Procedural History: The ejectment case, Civil Case No. 3782-P, was initially filed in the Court of First Instance of Pasay City by Manolito Bautista against the petitioners. The trial court ruled in favor of Manolito Bautista, ordering the ejectment of the defendants, demolition of their house, and payment of back rentals and attorney's fees. This decision was appealed to the Court of Appeals, which modified the judgment, affirming Manolito Bautista's ownership but subject to provisions regarding the house under Article 1678 of the Civil Code. Petitioners later filed a separate case to annul the trial court's judgment, which was dismissed and affirmed by the Supreme Court. Despite attempts to execute the ejectment order, it was held in abeyance due to pending related cases. In 1987, Manolito Bautista revived his motion for execution and demolition, which was granted by the respondent judge, leading to the issuance of a writ of execution and demolition. Petitioners' subsequent motions to quash the writ and for reconsideration were denied. Meanwhile, other parties sought to intervene, which was also denied. The petitioners then filed a petition for certiorari, prohibition, and injunction in the Court of Appeals, which was dismissed. A motion for reconsideration of this dismissal was also denied, leading to the present petition. The Petition: This is a petition for review on certiorari seeking to reverse the February 8, 1988 decision and April 22, 1988 resolution of the Court of Appeals. The Court of Appeals dismissed the petitioners' petition for certiorari, prohibition, and injunction, finding it insufficient in substance. The petitioners argue that the lower courts erred in their rulings and that the execution and demolition orders were improperly issued. However, during the pendency of this petition, it was revealed that the house of petitioners Leonarda Avedana and Purificacion Timbang had already been demolished and they had vacated the premises, rendering their prayer moot and academic. Furthermore, issues raised by other petitioners were allegedly resolved in a related Supreme Court case. Consequently, the Supreme Court found the petition to have become moot and academic.
Issue(s)
Whether the petition has become moot and academic due to the demolition of the petitioners' house and their vacation of the premises. Whether the CA erred in dismissing the petition for certiorari, prohibition, and injunction, and whether the underlying ejectment case has been effectively upheld.
Ruling
The petition is dismissed for having become moot and academic. The Court noted that the issues raised had already been resolved, particularly the demolition of the petitioners' house and their vacation of the premises, and that a related case had resolved all varied issues between the parties.
Ratio Decidendi
On Issue 1: The Court found that the petition had become moot and academic. This conclusion was based on the manifestation that the petitioners' house had already been demolished and they had vacated the premises. The Court cited jurisprudence holding that a case becomes moot and academic when the tenant has vacated the premises and possession has been delivered to the owner, or when the demolition of property has already occurred. On Issue 2: The Court implicitly affirmed the CA's dismissal of the petition for certiorari, prohibition, and injunction by dismissing the present petition on the ground of mootness. The CA had previously found the petition insufficient in substance. The Supreme Court's dismissal on mootness renders the CA's ruling on the merits of the petition for certiorari moot as well, but the underlying reason for the dismissal is the supervening events that rendered the issues academic. The Court also noted that the issues raised by petitioners Emiliana Bautista and Evangeline Bautista-Ortiz had already been resolved by this Court in a related case (G.R. No. 79958), further supporting the conclusion that the matter was settled. The Court's dismissal of the petition on mootness effectively upholds the finality of the CA's decision in the ejectment case, which declared Manolito Bautista as the lawful owner and ordered the defendants to vacate the premises, subject to Article 1678 of the Civil Code. The subsequent demolition and vacation of the premises by the petitioners rendered the execution of the judgment complete, thus mooting further appeals on the execution itself.
Main Doctrine
A petition is dismissed for having become moot and academic when the issues raised have already been resolved, particularly when the subject property has been demolished and possession thereof delivered to the owner, or when a related case has resolved all issues between the parties.