Pasig Printing v. Rockland Construction
REVERSALFacts
The Antecedents: MPLDC leased a property to ECRM, who assigned its rights, including the option to renew, to Rockland. Rockland erected a building and subleased portions to MC Home Depot. In December 2000, MPLDC demanded Rockland vacate. On January 11, 2001, Rockland filed a civil case for specific performance (Civil Case No. 68213) asking MPLDC to execute a 3-year extended lease. On August 22, 2001, MPLDC filed an unlawful detainer case (Civil Case No. 8788). The MeTC dismissed the unlawful detainer case, stating the issue was not possession but contract renewal. The Court, in G.R. No. 162924 (Tablante), later granted MPLDC's petition, stating issues in the specific performance case should be addressed in the unlawful detainer proceedings, and dismissed the specific performance case. Subsequently, the Court in Tablante declared the issue of possession moot and academic due to the expiration of the lease and closed and terminated the case. Procedural History: An indirect contempt case (SCA Case No. 2673) was filed against MPLDC for refusing to reconnect electricity. The RTC dismissed this case but awarded possession to MPLDC, ordering Rockland to refrain from exercising possessory rights. PPC intervened, claiming interest based on an alleged option to lease from MPLDC. The RTC granted PPC's intervention and ordered the implementation of its possession award, leading to the turnover of possession to PPC on November 16, 2004. On appeal, the CA affirmed the dismissal of the contempt case but annulled the award of possession to MPLDC and the writ of execution, nullifying the turnover to PPC. This CA decision was affirmed by the Supreme Court. Rockland sought restoration of possession, leading to flip-flopping RTC orders, with the last one (August 10, 2007) awarding possession to PPC. In its May 11, 2010 Decision, the CA ruled that an earlier order (March 29, 2007) directing the restoration of possession to Rockland be reinstated. Movants' motion for reconsideration was denied by the CA on August 27, 2010. Petitions for certiorari were filed before the Supreme Court, which dismissed them on February 2, 2011, reiterating that the issue of possession was moot and academic. The Petition: The movants (Pasig Printing Corporation, Republic of the Philippines, PCGG, and MPLDC) filed motions for reconsideration and/or clarification of the Supreme Court's February 2, 2011 Resolution, which dismissed their petitions as moot and academic. They argued that the dismissal affirmed an erroneous ruling that restored possession to Rockland despite the expiration of its lease.
Issue(s)
Whether the Court of Appeals erred in ordering the restoration of possession to Rockland Construction Company, Inc. despite the issue of possession having been declared moot and academic by the Supreme Court. Whether the Court of Appeals erred in not considering the Supreme Court's ruling in Mid-Pasig Land Development Corporation v. Mario Tablante, et al. (G.R. No. 162924) when it issued its May 11, 2010 Decision.
Ruling
The Supreme Court granted the motions for reconsideration, annulled and set aside the May 11, 2010 Decision and the August 27, 2010 Resolution of the Court of Appeals. The Court held that the Court of Appeals erred in ordering the restoration of possession to Rockland, as the issue of possession had already been declared moot and academic by the Supreme Court in Tablante due to the expiration of Rockland's lease.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in ordering the restoration of possession to Rockland Construction Company, Inc. despite the issue of possession having been declared moot and academic by the Supreme Court: The Court found merit in the movants' submission that the dismissal of the petitions would affirm an erroneous ruling which effectively restored the possession of the subject property to Rockland despite the expiration of its contract of lease. The Court reiterated its pronouncement in Mid-Pasig Land Development Corporation v. Mario Tablante, et al. (Tablante) that the issue of possession had become moot and academic. The Court emphasized the rule that courts decline jurisdiction of moot cases, as a declaration thereon would be of no practical use or value, and there is no actual substantial relief that can be granted. At the time the CA issued its assailed May 11, 2010 decision, the Supreme Court had already pronounced in Tablante the end of Rockland's claim over the subject property due to the expiration of its lease, meaning Rockland had no more possessory right. Therefore, the CA erred in ordering the restoration of possession to Rockland. On the issue of whether the Court of Appeals erred in not considering the Supreme Court's ruling in Mid-Pasig Land Development Corporation v. Mario Tablante, et al. (G.R. No. 162924) when it issued its May 11, 2010 Decision: The Court agreed that the CA erred. Even if the CA was not aware of the Tablante ruling, it had no factual or legal basis in ordering the restoration of possession to Rockland. The records clearly showed that the original lease contract had long expired in 2003. The Court stated that not to reverse and set aside the CA's decision would allow its disposition to remain intact, prejudicing the movants by allowing Rockland to claim possession despite the expiration of its lease. The Court decided the case on the merits in view of the peculiar circumstances, citing David v. Macapagal-Arroyo.
Main Doctrine
A court should not pass upon questions in which no actual interests are involved, declining jurisdiction of moot cases, as a declaration thereon would be of no practical use or value. Where an issue has become moot and academic, there is no justiciable controversy, and no actual substantial relief can be granted.