Lonzanida v. Sandiganbayan
REITERATIONFacts
The Antecedents: Petitioner Romeo D. Lonzanida was charged with 10 counts of Falsification of Public Document before the Sandiganbayan in 1988. He pleaded not guilty, and after trial, the Sandiganbayan found him guilty on October 20, 2000. Procedural History: Petitioner moved for reconsideration, which was pending. He then moved to treat his motion for reconsideration as a motion for new trial based on newly discovered evidence. The Sandiganbayan denied both motions separately. Subsequently, the Sandiganbayan granted petitioner's motion for reconsideration of the denial of his motion for new trial, in the interest of justice, and conducted hearings to receive new evidence. After the parties submitted their memoranda, the Sandiganbayan scheduled the promulgation of judgment. The Petition: Instead of promulgating a new judgment, the Sandiganbayan issued a Resolution dated January 21, 2003, declaring its October 20, 2000 Decision final and ordering petitioner's arrest. Petitioner and the Office of the Special Prosecutor (OSP) filed motions seeking clarification. The Sandiganbayan cancelled the scheduled promulgation and, on March 10, 2003, petitioner filed the instant petition for certiorari and prohibition to set aside the January 21, 2003 Resolution, praying for an injunctive order.
Issue(s)
Whether the Sandiganbayan gravely abused its discretion in issuing the Resolution dated January 21, 2003, declaring its Decision dated October 20, 2000, as final, despite granting a motion for new trial. Whether the petition has been rendered moot and academic by a supervening event.
Ruling
The Supreme Court dismissed the petition for having been rendered moot and academic by the Sandiganbayan's Decision promulgated on July 25, 2003. The Court noted that the Sandiganbayan's subsequent Decision not only found petitioner guilty of 10 counts of Falsification of Public Document and imposed the same penalty but also explicitly set aside the January 21, 2003 Resolution, thereby mooting the issues raised in the petition.
Ratio Decidendi
On the issue of whether the Sandiganbayan gravely abused its discretion in issuing the Resolution dated January 21, 2003: The Court found that the petition was rendered moot and academic by a supervening event. The object of the petition was to set aside the Sandiganbayan's January 21, 2003 Resolution which declared its October 20, 2000 Decision final. Petitioner argued that the Sandiganbayan's granting of a new trial had vacated the October 20, 2000 Decision. However, the Sandiganbayan subsequently promulgated a Decision on July 25, 2003, which not only found petitioner guilty as charged but also explicitly set aside the January 21, 2003 Resolution. This subsequent action by the Sandiganbayan rendered the issues raised in the petition academic. On the issue of whether the petition has been rendered moot and academic by a supervening event: The Court held that the petition was indeed moot and academic. A supervening event occurred when the Sandiganbayan promulgated its July 25, 2003 Decision. This Decision effectively resolved the underlying case by again finding the petitioner guilty and, crucially, by setting aside the very Resolution that the petitioner sought to nullify through the present petition. Therefore, the relief prayed for in the petition became superfluous as the Sandiganbayan itself corrected the procedural anomaly complained of.
Main Doctrine
A petition seeking to set aside a resolution declaring a prior decision final is rendered moot and academic by a subsequent decision of the same court that not only finds the petitioner guilty but also sets aside the assailed resolution.