Huibonhoa v. Concepcion
REITERATIONFacts
The Antecedents: Respondent Angel D. Concepcion, Sr. filed a complaint for accounting and damages against petitioner Veronique T. Huibonhoa, seeking injunctive relief to restrain Huibonhoa from performing her duties as manager of Poulex Supermarket and to compel her to turn over records. On July 13, 2001, the Acting Executive Judge issued a temporary restraining order (TRO) effective for seventy-two hours, restraining Huibonhoa from her managerial position and ordering the submission of records. On July 16, 2001, Huibonhoa and other stockholders filed an intra-corporate and derivative suit with a prayer for injunction and TRO, seeking to prevent Concepcion from interfering with the supermarket's management. On July 17, 2001, Judge Annang issued an order declaring the TRO's expiration but directing the continuous closure of the supermarket. Procedural History: Respondent Concepcion's complaint was raffled to Branch 28 of the RTC-Cabanatuan City. On July 20, 2001, Huibonhoa filed a petition for certiorari with the Court of Appeals (CA) assailing the July 13 and July 17 Orders of Judge Annang for grave abuse of discretion. The CA granted Huibonhoa's prayer for a TRO on July 23, 2001. On March 12, 2002, the CA dismissed Huibonhoa's petition for certiorari on the grounds of prematurity and forum shopping. Huibonhoa's motion for reconsideration was denied on May 27, 2002. The Petition: Petitioner Veronique T. Huibonhoa filed the instant petition for review on certiorari, assailing the CA's Decision and Resolution, arguing that the CA erred in dismissing her petition on the grounds of prematurity and forum shopping, and in not issuing a writ of certiorari to annul the trial court's orders.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the grounds of prematurity and forum shopping. Whether the Court of Appeals erred in not issuing a writ of certiorari to annul the July 13, 2001 and July 17, 2001 Orders of the trial court. Whether the petition has become moot and academic due to supervening events.
Ruling
The petition is DENIED for being moot and academic. No pronouncement as to costs.
Ratio Decidendi
On the issue of forum shopping: The Court found that a plain reading of the allegations in the complaint in Civil Case No. 4068-AF and the petition for certiorari filed with the CA would preclude affirming the CA's finding of forum shopping. The Court explained that not all elements of litis pendentia concurred, as there was no identity of parties, rights, or causes of action. Civil Case No. 4068-AF was a derivative suit and complaint for injunction instituted by stockholders, while the petition for certiorari was instituted by petitioner in her capacity as manager. The causes of action alleged were different, and the reliefs sought were also distinct. The only common thread was the TRO to prevent interference with the supermarket's operations, but this was considered incidental and not the main cause of action in both cases. The Court noted that with the settlement reached by the parties and the dismissal of their cases, the petitioner and her counsel were liberated from any risk of sanction for supposed forum shopping. On the annulment of the trial court's orders: Given that the petition was dismissed on the ground of mootness, the Court did not find it necessary to rule on the merits of whether the CA correctly upheld the trial court's orders. The expiration of the TRO by operation of law and the subsequent dismissal of the main case rendered the issue of the validity of these orders academic. The Court emphasized that it would abstain from expressing its opinion in a case where no legal relief is needed or called for, as the resolution of moot questions has no practical value. On the issue of mootness: The Supreme Court held that the petition had become moot and academic due to supervening events, specifically the dismissal of Civil Case No. 4065, the complaint for accounting and damages filed by respondent Concepcion. With the termination of the case wherein the assailed orders were issued, it became unnecessary for the Court to resolve whether the CA correctly upheld those orders. Furthermore, one of the assailed orders directed the issuance of a TRO, which, by operation of law, should have expired after 72 hours without the need for a judicial declaration to that effect. The Court reiterated the principle that courts of justice will not consider questions where no actual interests are involved and will decline jurisdiction over moot cases because there is no substantial relief to which the petitioner will be entitled.
Main Doctrine
A petition becomes moot and academic when the underlying case or the subject of the controversy has been terminated or resolved, rendering the resolution of the petition of no practical value. Furthermore, a petition may be dismissed for mootness if the issue involves a temporary restraining order that has already expired by operation of law.