Go v. Tabanda
REITERATIONFacts
The Antecedents: Petitioner Wilbur Go was proclaimed Mayor of Currimao, Ilocos Norte, after receiving a plurality of votes in the January 18, 1988 elections. Private respondent Cirilo M. Quilala filed an election protest (SPC No. 88-214) with the Commission on Elections (COMELEC), alleging irregularities, lack of notice, and prevention of his representatives from witnessing the canvass. The COMELEC dismissed the protest. Procedural History: Quilala filed a petition for certiorari with the Supreme Court (G.R. No. 82726) questioning the COMELEC's decision. Separately, Quilala instituted an election protest (EPC No. 012-17) before the Regional Trial Court (RTC) of Batac, Ilocos Norte, alleging rampant irregularities, vote-buying, and terrorism. The RTC initially granted Go an extension of five days to file an answer. However, the RTC later issued an Order dated May 30, 1988, cancelling the extension, striking off Go's Answer, and entering a general denial for failure to file within the prescribed period, citing Sections 254(b) and (f) of the Omnibus Election Code. Go's motion for reconsideration was denied. The Petition: Go filed a special civil action for certiorari with the Supreme Court, contesting the RTC's Order dated May 30, 1988, alleging grave abuse of discretion, without or in excess of jurisdiction amounting to lack of jurisdiction.
Issue(s)
Whether the RTC committed grave abuse of discretion in cancelling the granted extension of time to file an answer and entering a general denial. Whether the petition for certiorari has become moot and academic in light of a subsequent Supreme Court decision on the merits of the election dispute.
Ruling
The petition is DISMISSED for having become moot and academic. The election protest (EPC No. 012-17) is also dismissed for the same reason.
Ratio Decidendi
On the issue of extension of time: Although rendered moot by the decision on the merits, the Court noted that the question presented was whether the filing of a motion for extension of time to file an answer is allowed under the Omnibus Election Code. The RTC's cancellation of the extension and entry of a general denial were based on Sections 254(b) and (f) of the Omnibus Election Code. However, the Court's primary basis for dismissal was the supervening event of the final decision in G.R. No. 82726, which resolved the underlying election dispute on its merits. On the issue of mootness: The Court held that its decision in G.R. No. 82726, promulgated on August 13, 1990, which dismissed Quilala's election protest and affirmed Go's proclamation as Mayor, renders the present controversy moot and academic. This prior decision was a judgment on the merits and had become final and executory as of November 15, 1990. The Court reiterated the principle that where a decision on the merits has been rendered and has become final and executory, any action on procedural matters or issues becomes moot and academic, as adjudicating such issues would be a futile exercise. The Court will not determine abstract propositions or express opinions in cases where no practical relief can be granted due to supervening events. Since the election protest subject of the present petition substantially charged the same election offenses as those in the previously settled case, and the Supreme Court had already affirmed Go's proclamation, both the petition and the election protest should be dismissed.
Main Doctrine
A petition for certiorari concerning procedural matters in an election protest becomes moot and academic when a final and executory decision on the merits of a related case involving the same parties and subject matter has already been rendered.