Alonto, Jr. v. Memoracion
REITERATIONFacts
The Antecedents: This case concerns the dispute over the position of Vice-President of the Mindanao State University-Tawi-Tawi College of Technology and Oceanography (MSU-TCTO). Eldigario D. Gonzales, the private respondent, sought to reassume his position, which had been subject to a resolution by the MSU Board of Regents suspending him. The petitioners, Ahmad E. Alonto, Jr. and Amilussin Jumaani, along with the Board of Regents, were involved in the actions leading to Gonzales's suspension and the subsequent legal challenges. Procedural History: Eldigario D. Gonzales initiated Special Proceeding No. 6-5 before the Regional Trial Court of Tawi-Tawi, seeking to compel his reinstatement as Vice-President. The RTC issued a restraining order on February 2, 1988, which was later made permanent on March 14, 1988, nullifying the Board of Regents' resolution suspending Gonzales. The RTC also found Alonto, Jr. and Jumaani in contempt of court on April 19, 1988. Alonto and Jumaani filed a notice of appeal to the Court of Appeals regarding certain portions of the April 19, 1988 order. Despite this, they, along with the MSU Board of Regents, filed the instant petition with the Supreme Court. The Petition: The petitioners filed a petition for certiorari, prohibition, and mandamus with the Supreme Court, assailing the February 2, March 14, and April 19, 1988 orders of the RTC. They sought to reverse, annul, and set aside these orders. The Supreme Court noted that the petitioners had also filed an appeal to the Court of Appeals, which they initially characterized as a mere ad cautelam notice. However, upon further scrutiny, the Court found evidence of forum-shopping, as the case had proceeded to the Court of Appeals, including the filing of memoranda. The Supreme Court ultimately dismissed the petition due to forum-shopping and mootness, citing supervening events such as Gonzales's dismissal from service and the expiration of his term.
Issue(s)
Whether the petition should be dismissed due to forum-shopping. Whether the petition should be dismissed on the ground that the issues have become moot and academic due to supervening events. Whether the RTC orders granting the restraining order, making it permanent, declaring BOR Resolution No. 2 void, and finding petitioners in contempt were issued with grave abuse of discretion.
Ruling
The Supreme Court dismissed the petition. It found that the petitioners engaged in forum-shopping by filing a notice of appeal to the Court of Appeals while simultaneously pursuing a petition for certiorari, prohibition, and mandamus before the Supreme Court. Furthermore, the Court ruled that the issues raised in the petition had become moot and academic due to supervening events, namely, the dismissal of private respondent Gonzales from service by the MSU BOR for dishonesty and misconduct, the expiration of his term as Vice-President, and the decision of the Court of Appeals in CA-G.R. SP No. 14962 which set aside the RTC's findings of indirect contempt and the making of the temporary restraining order permanent. The Court also required petitioners and their counsel to show cause why no disciplinary action should be taken against them for falsehood and lack of candor.
Ratio Decidendi
On Forum-Shopping: The Court found that the petitioners engaged in forum-shopping, which is an act of malpractice that degrades the administration of justice. The petitioners filed a notice of appeal to the Court of Appeals regarding portions of the RTC's order, and subsequently filed a petition for certiorari, prohibition, and mandamus with the Supreme Court concerning the same orders. Evidence, including a resolution from the Court of Appeals in a related case, contradicted petitioners' claim that the appeal was not prosecuted. This act of filing multiple petitions seeking the same relief from different courts constitutes forum-shopping, a ground for the summary dismissal of both petitions. On Mootness and Academicness: The Court determined that the issues presented in the petition had become moot and academic due to supervening events. Firstly, the MSU BOR, through Resolution No. 139, series of 1988, dismissed private respondent Gonzales from service for dishonesty and misconduct. Secondly, Gonzales's term as Vice-President expired on March 16, 1989, as he was elected for a five-year term. These events rendered the original dispute regarding his assumption of office and suspension irrelevant. The Court also noted the decision of the Court of Appeals in CA-G.R. SP No. 14962, which set aside the RTC's contempt findings and the permanent restraining order, further contributing to the mootness of the petition before the Supreme Court. On the RTC Orders: While the petition was dismissed on procedural grounds (forum-shopping and mootness), the Court acknowledged the decision of the Court of Appeals in CA-G.R. SP No. 14962. This decision set aside the RTC's findings of indirect contempt against Alonto and Jumaani and the order making the temporary restraining order permanent. The Supreme Court stated that this decision, dealing with the main issues, served as adequate relief for the petitioners. The Court found that the trial court's orders, particularly those concerning contempt and the permanent restraining order, appeared arbitrary, justifying the Court of Appeals' action.
Main Doctrine
A petition for certiorari, prohibition, and mandamus will be dismissed if the petitioners engaged in forum-shopping by filing a similar petition in the Court of Appeals while the instant petition was pending before the Supreme Court, and if the issues have become moot and academic due to supervening events such as the dismissal of the private respondent from service and the expiration of his term.