Soriano vda. de Dabao v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Charlie and Mary Grace Iñigo-Dabao obtained a loan from Paluwagan ng Bayan Savings and Loan Bank (Paluwagan), executing a real estate mortgage over a parcel of land as security. The spouses defaulted on the loan, leading Paluwagan to initiate extra-judicial foreclosure proceedings. The property was sold at public auction, with Paluwagan as the sole bidder, and a certificate of sale was issued and registered. Procedural History: Carmen Soriano Vda. de Dabao, claiming to be the widow of the original owner and alleging forgery in the transfer of the property to the spouses Dabao, filed an action for annulment of deeds, cancellation of title, and recovery of properties. The Regional Trial Court (RTC) initially issued a temporary restraining order and later a preliminary injunction against Paluwagan. Paluwagan challenged these orders via a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion. The CA granted Paluwagan's petition, nullifying the RTC's orders. Carmen's motion for reconsideration was denied. The Petition: Carmen Soriano Vda. de Dabao filed the present petition for certiorari with the Supreme Court, assailing the CA's decision and resolution. She argued that the CA acted without or in excess of jurisdiction and with grave abuse of discretion by deviating from the general rule on preliminary injunctions and by prematurely declaring Paluwagan as a mortgagee in good faith. She sought to nullify the CA's rulings and to have the title restored to its status quo ante. However, subsequent developments, including an RTC decision declaring Charlie Dabao liable for falsification and allowing redemption, and a final and executory CA decision in a related appeal declaring Paluwagan the absolute owner as an innocent purchaser for value, rendered the petition moot and academic.
Issue(s)
Whether the Supreme Court should annul the Court of Appeals' decision and resolution for allegedly acting with grave abuse of discretion in setting aside the preliminary injunction, a question rendered moot by subsequent events. Whether the Court of Appeals erred in declaring Paluwagan ng Bayan Savings and Loan Bank as a mortgagee in good faith, considering this was allegedly a factual and litigable issue before the RTC, a finding effectively affirmed by the Supreme Court's judicial notice of the CA's decision. Whether the petition before the Supreme Court has become moot and academic due to subsequent decisions in related cases.
Ruling
The Supreme Court dismissed the petition for certiorari, holding that it had become moot and academic. The Court took judicial notice of the final and executory decision of the Court of Appeals in CA-G.R. CV No. 60399, which declared Paluwagan ng Bayan Savings and Loan Bank as the absolute owner of the property as an innocent purchaser for value. This subsequent ruling rendered the reliefs prayed for by the petitioner in the present petition, as well as in the original Civil Case No. 90-2092, no longer legally feasible.
Ratio Decidendi
On the alleged grave abuse of discretion by the Court of Appeals: While the Court did not directly rule on the merits of the alleged grave abuse of discretion in setting aside the preliminary injunction, its dismissal of the petition on the ground of mootness rendered this issue moot. The Court of Appeals had previously found that the RTC committed grave abuse of discretion in issuing the preliminary injunction, considering Paluwagan's status as an alleged innocent mortgagee in good faith. However, the subsequent definitive ruling on ownership by the CA in CA-G.R. CV No. 60399 superseded the need to revisit the propriety of the preliminary injunction at this stage. The final determination of ownership by the appellate court rendered the interim relief of injunction irrelevant. On the declaration of Paluwagan as an innocent mortgagee in good faith: The Supreme Court, by taking judicial notice of the CA's decision in CA-G.R. CV No. 60399, effectively affirmed the finding that Paluwagan was an innocent purchaser for value. This decision declared Paluwagan as the absolute owner of the property, a conclusion that inherently validated its good faith in acquiring the property through the foreclosure sale. The fact that Paluwagan was the sole bidder in the foreclosure sale was a significant factor in the CA's determination of its status as an innocent purchaser for value. This final determination by the appellate court resolved the factual issue that the petitioner argued was still litigable before the RTC. On the issue of mootness: The Supreme Court held that the petition had become moot and academic. An issue becomes moot and academic when it ceases to present a justiciable controversy, rendering any declaration on the issue of no practical use or value. In this case, the subsequent final and executory decision of the Court of Appeals in CA-G.R. CV No. 60399, which declared Paluwagan ng Bayan Savings and Loan Bank as the absolute owner of the property as an innocent purchaser for value, effectively resolved the underlying dispute regarding ownership and the right to dispose of the property. Therefore, the petitioner's prayer to enjoin the bank from alienating the property and to restore the status quo ante was no longer legally feasible. The Court's taking judicial notice of this subsequent decision under Rule 129 of the Rules of Court was crucial in its determination.
Main Doctrine
A petition for certiorari seeking to annul a Court of Appeals decision that set aside a preliminary injunction becomes moot and academic when a subsequent final and executory decision by the Court of Appeals declares the respondent bank as the absolute owner of the property, rendering the reliefs prayed for no longer legally feasible.