Tatad v. Commission on Appointments
REITERATIONFacts
The Antecedents: Petitioner Francisco S. Tatad challenged the Commission on Appointments' (Commission) consent to the appointment of former Vice President Teofisto Guingona, Jr. as Ambassador Extraordinary and Plenipotentiary to the People's Republic of China, with concurrent jurisdiction over the Democratic People's Republic of Korea and Mongolia. Petitioner argued that the appointment was void as Guingona was over seventy (70) years old at the time, allegedly contrary to Republic Act No. 7157 (Philippine Foreign Service Act of 1991). Procedural History: The Regional Trial Court (RTC) dismissed petitioner's complaint for declaration of nullity. The RTC denied petitioner's Motion for Judgment on the Pleadings and granted the respondent Commission's Motion to Dismiss, finding the case moot after Ambassador Guingona resigned from the position. The Court of Appeals (CA) affirmed the RTC's dismissal. The Petition: Petitioner elevated the case to the Supreme Court, reiterating his arguments that the appointment was illegal and that the resignation did not moot the case, as there should be a continuing determination of responsibility for the alleged illegal act.
Issue(s)
Whether the resignation of former Vice President Teofisto Guingona, Jr. as Ambassador rendered the case moot and academic. Whether the Supreme Court should still resolve the issues presented to determine if the Commission on Appointments violated the law and public policy, despite the resignation.
Ruling
The Supreme Court denied the petition, affirming the dismissal of the case by the RTC and CA. The Court held that the resignation of Ambassador Guingona rendered the issues moot and academic, as there was no longer an actual controversy or substantial relief that could be granted.
Ratio Decidendi
On the issue of mootness due to resignation: The Supreme Court agreed with the lower courts that the resignation of former Vice President Guingona as Ambassador rendered the issues raised in the petition moot and academic. The Court explained that an issue becomes moot and academic when it ceases to present a justiciable controversy, meaning there is no actual substantial relief that a petitioner would be entitled to, and which would be negated by the dismissal of the petition. In this instance, the resignation meant that the appointee no longer occupied the subject position, thus there was no longer an illegal appointment to speak of. The Court reiterated its consistent holding that courts will not determine a moot question in a case where no practical relief will be granted. On the insistence for a ruling on legality despite mootness: The Supreme Court found petitioner's insistence that the issues must be resolved for the public to know whether the Commission violated the law and public policy to be mistaken. The Court clarified that because the present case lacked an actual controversy, any resolution of the issues presented would not result in an adjudication of the rights of the parties. Instead, such a resolution would merely take the nature of an advisory opinion. The Court emphasized its role in resolving actual cases and controversies, not in rendering advisory opinions, citing Ticzon v. Video Post Manila, Inc..
Main Doctrine
A case becomes moot and academic when it ceases to present a justiciable controversy, rendering any resolution of the issues without practical effect or substantial relief to the parties. Courts will not render advisory opinions on moot questions.