Quiño v. Commission on Elections
REITERATIONFacts
1. The Antecedents: During the May 10, 2010 elections, Joel P. Quiño and Ritchie R. Wagas vied for the position of Mayor in Compostela, Cebu. Petitioners Mary Antonette C. Dangoy, Josephine T. Abing, Joy Ann P. Cabatingan, Tessa P. Cang, Wilfredo T. Calo, Homer C. Canen, Jose L. Cagang, Alberto Cabatingan, and Francisco T. Oliverio ran for Vice-Mayor and Municipal Councilors, respectively. Initial canvassing results showed Quiño with 11,719 votes against Wagas' 9,338 votes, leading to the proclamation of Quiño and the other petitioners by the Municipal Board of Canvassers (MBOC) on May 11, 2010. 2. Procedural History: On May 14, 2010, Wagas filed an Election Protest against Quiño before the Regional Trial Court (RTC) and a petition for annulment of proclamation with the Commission on Elections (COMELEC) on May 21, 2010. Wagas alleged that the Audit/Print Logs of the MBOC's Consolidating Machine did not reflect fourteen (14) clustered precincts, and that despite this absence, the machine generated Certificates of Canvass and Statements of Votes (SOV), suggesting falsified election returns. The COMELEC Second Division, on June 28, 2010, issued an order suspending the proclamation and directing Wagas to amend his petition to implead indispensable parties. Following the filing of an amended petition and the petitioners' answer, the COMELEC Second Division, on January 12, 2011, issued a resolution granting the petition and annulling the proclamation of the winning candidates. This resolution was affirmed by the COMELEC En Banc on June 13, 2011, despite a dissenting opinion. Subsequent proceedings involved Wagas' request to transfer the venue of canvassing, the constitution of a new Board of Canvassers, and Wagas' motion for a manual recount, which was denied by the COMELEC En Banc. This denial was subsequently upheld by the Supreme Court in G.R. No. 200505. 3. The Petition: The petitioners filed a petition for certiorari under Rule 65 in conjunction with Section 2, Rule 64 of the 1997 Rules of Civil Procedure, as amended, seeking to annul the COMELEC's resolutions dated January 12, 2011, and June 13, 2011. They argued that the COMELEC gravely abused its discretion in annulling their proclamation. However, during the pendency of the petition before the Supreme Court, the Special Board of Canvassers of Compostela, Cebu, proclaimed the petitioners as the winning candidates. Consequently, the Supreme Court dismissed the petition on the ground of mootness, as the reliefs prayed for had become academic due to the subsequent proclamation and the absence of an actual controversy.
Issue(s)
Whether the petition challenging the COMELEC's annulment of the petitioners' proclamation has become moot and academic due to their subsequent re-proclamation by a Special Board of Canvassers.
Ruling
The present petition for certiorari is DISMISSED on the ground of MOOTNESS.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the case has become moot and academic because the Special Board of Canvassers (SBOC) of Compostela, Cebu, already proclaimed the petitioners as the winning candidates for municipal mayor, vice-mayor, and councilors. This subsequent proclamation, as manifested by respondent Wagas on August 16, 2012, effectively granted the relief sought by the petitioners in their original petition. Under Philippine jurisprudence, a case is considered moot when it ceases to present a justiciable controversy by virtue of supervening events, so that a declaration thereon would be of no practical use or value. Applying the ruling in Ocampo v. House of Representatives Electoral Tribunal, the Court emphasized that it will not consider questions in which no actual interests are involved. Since the petitioners have been proclaimed and are presumably holding office, there is no actual substantial relief to which they would be entitled that has not already been realized. Therefore, resolving the merits of the COMELEC's previous annulment of the first proclamation would serve no useful purpose and would result in a mere advisory opinion.
Main Doctrine
The Mootness Doctrine dictates that the Court will dismiss a case when supervening events have rendered the issues academic, such that any judgment would have no practical legal effect. In election cases, the subsequent proclamation of the petitioners by a Special Board of Canvassers (SBOC) during the pendency of a petition challenging a prior annulment of their proclamation makes the petition moot. The Court's function is to decide actual controversies, not to provide advisory opinions on issues where the relief sought has already been obtained or the dispute has ceased to exist.