Sarmiento v. Magsino
REITERATIONFacts
The Antecedents: Respondent spouses Magsino filed a Complaint for Specific Performance and Damages against spouses Calderon for the delivery of owner's duplicate copies of TCT Nos. T-256745 and T-256746, or in the alternative, reimbursement of ₱383,013.70 plus interest. The RTC Branch 93 granted the alternative relief, ordering spouses Calderon to reimburse the said amount. This decision became final and executory. Subsequently, the subject properties, still registered in the names of spouses Calderon but already sold to petitioners Sarmiento and Amarillo, were levied and sold at public auction to respondent spouses Magsino. New TCTs were issued in the names of respondent spouses Magsino. Respondent spouses Magsino then filed a Petition for a writ of possession, which was granted by RTC Branch 93, leading to the eviction of petitioners Sarmiento and Amarillo and the turnover of possession to respondent spouses Magsino. Procedural History: Petitioners Sarmiento and Amarillo filed a separate Complaint for Recovery of Possession and Ownership against respondent spouses Magsino before RTC Branch 31, seeking a temporary restraining order and preliminary injunction to restore possession to them and to cancel the TCTs in the names of respondent spouses. Respondent spouses moved to dismiss the complaint on grounds including lack of jurisdiction, another action pending, and res judicata. RTC Branch 31 denied the motion to dismiss but granted petitioners' application for a writ of preliminary injunction, restoring possession to petitioners. Respondent spouses filed a Petition for Certiorari with the Court of Appeals, which set aside the RTC Branch 31 orders, ruling that RTC Branch 31 interfered with the judgment of a co-equal court (RTC Branch 93). Petitioners' motion for reconsideration was denied. The Petition: Petitioners Sarmiento and Amarillo filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' Decision and Resolution, arguing that the Court of Appeals erred in applying the doctrine of finality of judgment and non-interference with a co-equal court, and in ignoring Rule 39, Section 16 on Third Party Claims. They also alleged grave abuse of discretion by the Court of Appeals.
Issue(s)
Whether the Court of Appeals erred in ruling that RTC Branch 31 interfered with the judgment of RTC Branch 93, a co-equal court, by issuing a writ of preliminary injunction; and whether the doctrine of finality of judgment and non-interference with a co-equal court applies to the petitioners. Whether the Court of Appeals erred in applying the doctrine of finality of judgment and non-interference with a co-equal court against the petitioners, who were not parties to the original case before RTC Branch 93, considering the supervening event of the main case being decided on its merits.
Ruling
The Supreme Court denied the petition for being moot and academic. The Court noted that RTC Branch 31 had already decided the main case filed by petitioners in their favor on January 3, 2013, ordering the cancellation of respondent spouses' TCTs and making the injunction permanent. Petitioners also declared that they remained in possession of the subject properties. Given these developments, the issues raised in the petition before the Supreme Court, which pertained to incidents of the main case, had become moot and academic.
Ratio Decidendi
On the issue of interference with a co-equal court and the application of finality of judgment: The Supreme Court noted that the main case filed by the petitioners before RTC Branch 31 had already been decided on the merits in their favor. This subsequent decision rendered the issues concerning the preliminary injunction and the alleged interference with a co-equal court moot and academic. The Court reiterated the principle that courts will not consider questions where no actual interests are involved and decline jurisdiction of moot cases, as a declaration thereon would be of no practical use or value. The subsequent decision on the merits by RTC Branch 31, which favored the petitioners and made the injunction permanent, effectively resolved the underlying dispute that gave rise to the petition before the Supreme Court. Therefore, any ruling on the propriety of the preliminary injunction or the alleged interference with a co-equal court would no longer provide any substantial relief to the parties. The Court emphasized that when the merits of the main case have been decided, the incidental issues, such as those related to provisional remedies, become moot. The Supreme Court's resolution of the petition was based on the supervening event of the main case being decided on its merits. This rendered the discussion of whether RTC Branch 31 interfered with RTC Branch 93's judgment unnecessary. The Court's pronouncement that the petition was moot and academic meant that it did not delve into the merits of the arguments regarding the applicability of the doctrine of non-interference or the rights of third-party claimants under Rule 39, Section 16. On the application of the doctrine of finality of judgment and non-interference with a co-equal court, considering the supervening event: The focus shifted to the fact that the underlying dispute had been resolved, making the interlocutory issues moot. The Court's decision to dismiss the petition for being moot and academic signifies that it avoids passing upon issues that have lost their practical significance due to subsequent events. The Court's adherence to the principle of avoiding moot cases is a fundamental aspect of judicial efficiency and the proper exercise of its jurisdiction.
Main Doctrine
A petition for review on certiorari becomes moot and academic when the main case, which spawned the incident subject of the petition, has already been decided on the merits, rendering any resolution of the incident moot and academic.