Tantoy v. Abrogar
REITERATIONFacts
1. The Antecedents: Respondent Barangay Councilor Abner Dreu filed an administrative complaint against petitioner Barangay Captain Ramonito Tantoy, Sr. The City Council of Makati recommended Tantoy's removal, but the Office of the President reversed this decision upon appeal. Subsequently, the City of Makati moved for reconsideration of the Office of the President's resolution. 2. Procedural History: While the motion for reconsideration was pending before the Office of the President, respondent Dreu filed a Petition for Preliminary Injunction with the Regional Trial Court (RTC) to prevent the enforcement of the Office of the President's decision. The RTC initially denied the petition but later reversed its decision and issued the injunction. After the Office of the President denied the motion for reconsideration, petitioner filed a Motion to Dismiss and Dissolve the Writ of Preliminary Injunction with the RTC. However, before the RTC could act on this motion, petitioner filed a Petition for Certiorari and Prohibition with the Court of Appeals. Subsequently, the RTC lifted the injunction and dismissed the case, leading the Court of Appeals to dismiss petitioner's petition as moot and academic. 3. The Petition: Petitioner filed a petition for review with the Supreme Court, arguing that the RTC lacked jurisdiction to issue a writ of preliminary injunction against a co-equal body and that the case was not moot despite the dismissal of the RTC case, as he suffered damages from the allegedly void writ. Petitioner also contended that the RTC could no longer dissolve the writ once the matter was elevated to the appellate court. The Supreme Court is asked to resolve whether the trial court had jurisdiction to issue and dissolve the writ and whether the case is moot and academic.
Issue(s)
Whether the Regional Trial Court had jurisdiction to issue a writ of preliminary injunction against the Office of the President, and whether the case became moot and academic despite the dismissal of the civil case, considering the alleged enforcement of a void writ of preliminary injunction. Whether the trial court could dissolve the writ of preliminary injunction after the issue was elevated to the appellate court.
Ruling
The Supreme Court denied the petition and affirmed the Decision of the Court of Appeals, holding that the case was moot and academic. The Court also found that the petitioner violated the rule against forum shopping.
Ratio Decidendi
On the issue of mootness and the RTC's jurisdiction: The Court affirmed the Court of Appeals' ruling that the case was moot and academic. A case becomes moot and academic when there is no longer an actual controversy between the parties or no useful purpose can be served in passing upon the merits. Since the RTC had already lifted the writ of injunction, there was nothing left for the Court of Appeals to annul or act upon. The appellate court was correct in ruling that the case had become moot and academic, notwithstanding the petitioner's claim of damages. The claim for damages should have been directed against the injunction bond. Furthermore, a finding that the trial court had no jurisdiction to issue the writ of preliminary injunction entails a ruling that the writ and all the proceedings held for that purpose are null and void. Such a ruling would render not only the writ of preliminary injunction without force and effect but also the injunction bond posted for the purpose, legally non-existent. Therefore, any ruling on the issue of jurisdiction would not serve the purpose for which the petition was filed, which was to claim for damages. On the issue of the trial court's authority to dissolve the writ: The Court found that the petitioner violated the rule against forum shopping. He filed a petition for certiorari and prohibition before the Court of Appeals without waiting for the resolution of his motion to dismiss the case and to dissolve the writ filed before the trial court. It was precisely because of his motion that the trial court lifted the writ of preliminary injunction and dismissed the case. Therefore, the petitioner could not complain about an action he himself initiated. His reliance on Joy Mart Consolidated Corporation v. Court of Appeals was misplaced as that case involved a respondent adjudged guilty of forum shopping for filing simultaneous petitions, which is analogous to the petitioner's actions in this case.
Main Doctrine
A case becomes moot and academic when there is no longer an actual controversy between the parties or no useful purpose can be served in passing upon the merits. A finding that the trial court had no jurisdiction to issue a writ of preliminary injunction entails a ruling that the writ and all proceedings held for that purpose are null and void.