Natal v. Caballes
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for quasi-delict and tort against Marcopper Mining Corporation (Marcopper) and Placer Dome Inc. for damages due to flooding and siltation of the Mogpog river, allegedly caused by the breach of Marcopper's Maguila-guila dam. Procedural History: Petitioners filed a Motion for Production and Inspection of Objects/Property on October 14, 2008, seeking to require Marcopper to produce specific documents and allow inspection of its mining facilities. The respondent Judge issued orders for Marcopper to comment and for petitioners to reply, deeming the motion submitted for resolution. Despite two motions for early resolution filed by petitioners, the respondent Judge failed to act on the motion for almost fourteen (14) months. The Petition: Petitioners filed a petition for mandamus to compel the respondent Judge to resolve their motion, citing the 3-month period mandated by Section 15, Article VIII of the 1987 Constitution.
Issue(s)
Whether the petition for mandamus should be granted to compel the respondent Judge to resolve the petitioners' Motion for Production and Inspection of Objects/Property. Whether the petition has become moot.
Ruling
The petition is dismissed on the ground of mootness. The Supreme Court noted the significant delay in the resolution of the motion but stated that the administrative consequences are beyond their authority to rule upon in this case, as an administrative case has already been filed with the Office of the Court Administrator.
Ratio Decidendi
On the issue of whether the petition for mandamus should be granted: The Supreme Court dismissed the petition for mandamus. The Court held that an action is considered "moot" when it no longer presents a justiciable controversy because the issues involved have become academic or when the matter in dispute has already been resolved, and no longer requires judicial intervention. In this case, the respondent Judge had already issued an order on March 11, 2010, resolving the petitioners' motion for production and inspection. Therefore, there was nothing left for the Supreme Court to act upon. The Court reiterated the principle that courts will not sit for the purpose of trying moot cases and spend time in deciding questions whose resolution cannot in any way affect the rights of the person or persons presenting them. The Court acknowledged the delay in the resolution of the motion, which took the Judge almost fourteen (14) months to act upon. However, the administrative consequences of this delay were deemed beyond the Court's authority to rule upon in this specific petition, as an administrative case had already been filed concerning the matter. Hence, the administrative matter was left for consideration in that separate case. On the issue of whether the petition has become moot: As stated above, the Court held that an action is considered "moot" when it no longer presents a justiciable controversy because the issues involved have become academic or when the matter in dispute has already been resolved, and no longer requires judicial intervention. In this case, the respondent Judge had already issued an order on March 11, 2010, resolving the petitioners' motion for production and inspection. Therefore, there was nothing left for the Supreme Court to act upon.
Main Doctrine
A petition for mandamus to compel a judge to resolve a motion is rendered moot when the judge subsequently resolves the motion, even if there was a significant delay in the resolution.