Lu v. Chiong
REITERATIONFacts
The Antecedents: This case originated from two separate complaints filed by Marissa Lu Chiong and Cristina Lu Ng (respondents) against Emmanuel M. Lu, Rommel M. Lu, Carmela M. Lu, Karen Grace P. Lu, and James Michael Lu (petitioners). The complaints, SEC Case No. 99-2014-C and SEC Case No. 100-2014-C, sought the nullification of stockholder's meetings, elections of directors and officers, and related documents for Remcor Industrial and Manufacturing Corporation and Soutech Development Corporation, respectively. The respondents questioned the propriety of the stockholder meetings and elections held on March 4, 2014, for both companies. Procedural History: The cases were initially raffled to Branch 34 of the Regional Trial Court (RTC) of Calamba City, Laguna. During the proceedings, the respondents filed motions for the inhibition of Presiding Judge Maria Florencia Formes-Baculo, citing alleged bias and partiality. Judge Formes-Baculo granted these motions, voluntarily inhibiting herself from the cases. Subsequently, the respondents filed a Consolidated Petition for certiorari and prohibition with the Court of Appeals (CA) challenging the inhibition orders. The CA granted this petition, reversing the RTC's inhibition orders and remanding the cases to Branch 34. The petitioners then filed a motion for reconsideration, which the CA denied. This led to the petitioners filing the present petition for review on certiorari with the Supreme Court. The Petition: The petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. They argued that the CA erred in reversing the RTC judge's inhibition. However, the Supreme Court found that the main issue had become moot and academic. This was because the RTC, Branch 35, had already issued a Consolidated Decision on July 13, 2015, which dismissed the respondents' complaints on the merits and upheld the validity of the contested stockholder meetings and elections. This decision was promulgated before the CA issued its challenged ruling, rendering the CA's proceedings moot.
Issue(s)
Whether the Court of Appeals erred in reversing the voluntary inhibition of the Regional Trial Court Judge, an issue that is now moot due to subsequent events. Whether the petition before the Court of Appeals was rendered moot and academic by the subsequent Consolidated Decision of another branch of the Regional Trial Court on the merits of the main cases.
Ruling
The Supreme Court granted the petition. It reversed and set aside the Court of Appeals' Decision dated September 11, 2015, and Resolution dated December 14, 2015, and entered a new one dismissing the respondents' petition for certiorari and prohibition on the ground of mootness.
Ratio Decidendi
On the issue of the Court of Appeals' error in reversing the voluntary inhibition: The Court held that the promulgation of the Consolidated Decision by RTC, Branch 35 on July 13, 2015, which finally disposed of the main issues in SEC Case Nos. 99-2014-C and 100-2014-C on the merits, rendered the petition for certiorari before the Court of Appeals (CA-G.R. SP No. 139683) moot and academic. The CA's subsequent order for the return of records to Branch 34 for speedy trial was rendered moot by Branch 35's prior resolution of the main cases. The Court reiterated the settled rule that an issue becomes moot and academic when it ceases to present a justiciable controversy, and courts generally decline jurisdiction over such actions or dismiss them on the ground of mootness. The existence of the Consolidated Decision, which was later appealed by the respondents themselves, further underscored the mootness of the CA proceedings concerning the inhibition orders. Consequently, the Court found this ground sufficient to grant the present petition, rendering it unnecessary to rule on the other grounds raised by the petitioners. On the issue of mootness of the petition before the Court of Appeals: The Court emphasized that the mere pendency of a special civil action for certiorari does not automatically interrupt the proceedings in the lower court. Jurisdiction over the main actions attached to the RTC of Calamba City, not exclusively to its branches or judges. Therefore, Branch 35 had the authority to proceed with the main actions notwithstanding the pendency of the CA petition. The Court reiterated the settled rule that an issue becomes moot and academic when it ceases to present a justiciable controversy, and courts generally decline jurisdiction over such actions or dismiss them on the ground of mootness.
Main Doctrine
A petition for certiorari becomes moot and academic when the main case it pertains to has already been decided on the merits by the lower court, rendering the appellate court's resolution of the certiorari petition without practical use or value.