International Pipes, Inc. v. F.F. Cruz & Co., Inc.
REITERATIONFacts
The Antecedents: Respondent F. F. Cruz & Co., Inc. (FF Cruz) was the winning bidder for the supply, delivery, and installation of water pipes for project APM-01 of the Angat Water Supply Optimization Program (ASOP). The Metropolitan Waterworks and Sewerage System (MWSS) rejected all bids and opted to undertake the project by administration. FF Cruz filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals (CA) assailing the MWSS resolution. Procedural History: The CA nullified and set aside the MWSS resolution. Subsequently, petitioners International Pipes, Inc. (IPI) and Italit Construction and Development Corporation (ITALIT) filed a motion for leave to intervene and to admit their comment-in-intervention with the CA. The CA denied their motion, finding that petitioners failed to demonstrate a legal interest in the matter in litigation or that they would be adversely affected. The Petition: Petitioners appealed the CA's denial of their motion for intervention to the Supreme Court via certiorari.
Issue(s)
Whether petitioners have demonstrated a legal interest sufficient to warrant intervention. Whether the petition for intervention has become moot and academic due to the termination of the main case.
Ruling
The Supreme Court dismissed the petition, holding that it had become functus officio. The Court noted that the main case, involving the controversies between FF Cruz and MWSS for projects APM-01 and APM-02, had been terminated by a compromise agreement approved by the Supreme Court. Since intervention is merely ancillary and supplemental to an existing litigation, and the main case was already closed and terminated, there was no longer a case in which petitioners could intervene.
Ratio Decidendi
On the issue of legal interest for intervention: The Court held that there was no need to rule on the specific merits of whether petitioners possessed the requisite legal interest for intervention or the timeliness of their motion, as the termination of the main case rendered these issues moot. On the issue of mootness: The Court held that the petition had become functus officio. Intervention is not an independent action but is merely ancillary and supplemental to an existing litigation. In this case, the main controversy between F. F. Cruz & Co., Inc. (FF Cruz) and the Metropolitan Waterworks and Sewerage System (MWSS) concerning projects APM-01 and APM-02 was amicably settled through a compromise agreement. This compromise agreement was subsequently approved by the Supreme Court, leading to the closure and termination of the related cases, including G.R. No. 127653 (which involved the CA-G.R. SP No. 38797, the case in which petitioners sought to intervene) and G.R. No. 128634. As the principal action had already been terminated, there was no longer any existing litigation to which the intervention could be attached. Therefore, the motion for intervention, and consequently the petition before the Supreme Court, had lost their purpose and legal effect. The Court cited several precedents, including Republic v. Sandiganbayan, Chavez v. Ongpin, and Islamic Directorate of the Philippines v. Court of Appeals, to support the principle that intervention cannot exist as an independent action and is dependent on the existence of a main case.
Main Doctrine
A petition for intervention becomes moot and academic, rendering the Court's action functus officio, when the main case in which intervention was sought has been terminated by a compromise agreement approved by the Supreme Court.