Sales v. Commission on Elections
REITERATIONFacts
1. The Antecedents: Petitioner Marlon T. Sales and respondent Thelma Benemerito were candidates for Mayor of Pagudpud, Ilocos Norte, in the May 10, 2004 local elections. Following the proclamation of Sales as the winner, Benemerito filed an election protest, alleging that literate voters were allowed to vote as illiterates. Sales filed a counter-protest. 2. Procedural History: The Regional Trial Court (RTC) ordered the revision of ballots and subsequently denied Sales's opposition to the verification of Voter's Registration Records. The RTC initially denied Benemerito's motion for matching of ballots, requiring proof that literate voters were allowed to vote as illiterates. However, the RTC later granted Benemerito's motion for partial reconsideration, setting a hearing for evidence and allowing the matching of ballots. Sales's motion for reconsideration of this order was denied. Sales then filed a Petition for Certiorari with the Commission on Elections (COMELEC), which dismissed the petition for lack of merit and directed the RTC to proceed with the hearing. The COMELEC subsequently denied Sales's motion for reconsideration. 3. The Petition: This Petition for Certiorari under Rule 65 of the Rules of Court challenges the COMELEC's Resolutions affirming the RTC's Orders. Petitioner Sales argues that the COMELEC committed grave abuse of discretion. However, the Court notes that national and local elections have since been held, and the contested term of office for Mayor of Pagudpud, Ilocos Norte, has expired. Consequently, the petition has become moot and academic, as no practical relief can be granted.
Issue(s)
Whether the Commission on Elections committed grave abuse of discretion in affirming the Regional Trial Court's Orders. Whether the Petition has become moot and academic due to the expiration of the contested term of office.
Ruling
The Supreme Court dismissed the Petition for being moot and academic. The Court held that since the term of office contested in the election protest (Mayor of Pagudpud, Ilocos Norte, for the 2004-2007 term) had already expired on June 30, 2007, no practical relief could be granted. The dispositive portion of the Resolution stated: "IN VIEW OF THE FOREGOING, the Petition is DISMISSED for being MOOT and ACADEMIC."
Ratio Decidendi
The Court did not explicitly address whether the Commission on Elections committed grave abuse of discretion in affirming the Regional Trial Court's Orders because the case was rendered moot. Therefore, there is no ratio decidendi on this issue. On the issue of mootness: The Court held that the petition had become moot and academic. The term of office for which Marlon T. Sales was elected Mayor of Pagudpud, Ilocos Norte, in the 10 May 2004 elections expired on 30 June 2007. The subsequent national and local elections held on 14 May 2007, with winners assuming office on 1 July 2007, rendered the present controversy concerning the 2004 election results without practical legal effect. Courts will not determine a moot question in a case where no practical relief can be granted, nor will they indulge in academic discussions of issues that have lost their justiciable character. The expiration of the contested term of office has the effect of rendering an election protest moot and academic, as established in jurisprudence. The Court cited Malaluan v. COMELEC, Yorac v. Magalona, Garcia v. COMELEC, and Gancho-on v. Secretary of Labor and Employment to support the principle that courts decline jurisdiction over moot cases where no substantial rights are involved or no practical relief can be afforded. Therefore, passing on the merits of Sales's contentions would serve no useful purpose.
Main Doctrine
A petition challenging the results of an election becomes moot and academic when the term of office contested has already expired, as no practical relief can be granted.