Professional Regulation Commission v. Philippine Society of Mechanical Engineers
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from conflicting elections for the 2016 National Board of Directors and Officers of the Philippine Society of Mechanical Engineers (PSME). Following the October 2015 elections, a protest was filed alleging irregularities in the balloting process. This led to a PSME-COMELEC resolution annulling certain votes and declaring a different set of directors elected. Subsequently, a separate intra-corporate case was filed concerning the validity of these elections. 2. Procedural History: The PSME filed a petition for the declaration of nullity of PRC Office Order No. 2016-56, which recognized Engr. Leandro A. Conti as the 2016 PSME National President for the purpose of issuing Certificates of Good Standing. This petition was initially dismissed by the Regional Trial Court (RTC) Manila, Branch 6, on grounds of mootness and res judicata, citing a separate decision from RTC Manila, Branch 24, in an intra-corporate dispute. The Court of Appeals reversed this dismissal, finding that the RTC Manila, Branch 24 decision did not declare Engr. Conti as president and that res judicata did not apply. The Professional Regulation Commission (PRC), as petitioner, now seeks review of the Court of Appeals' decision. 3. The Petition: This case is before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The petitioner, the Professional Regulation Commission (PRC), argues that the Court of Appeals erred in reversing the RTC's dismissal of the nullity case. The PRC contends that the petition for nullity of its Office Order No. 2016-56 was rendered moot by the decision of RTC Manila, Branch 24, in the intra-corporate case, which declared void the election of Engr. Conti as the 2016 PSME National President. The PRC asserts that its office order was merely provisional and has since been superseded by subsequent events and decisions, rendering any further adjudication of the nullity case pointless.
Issue(s)
Whether the petition for declaration of nullity of PRC Office Order No. 2016-56 pending before the RTC Manila-Br. 6 has been rendered moot in view of the decision of the RTC Manila-Br. 24 in the intra-corporate case declaring void the election of Engr. Conti as 2016 PSME National President; and whether the respondent PSME would obtain any actual or substantial relief by pursuing the declaration of nullity, considering supervening events.
Ruling
The petition is GRANTED. The Decision dated March 10, 2020 and Resolution dated September 21, 2020 of the Court of Appeals in CA-G.R. CV No. 110943 are REVERSED and SET ASIDE. Civil Case No. 16-135469 is DISMISSED for being moot.
Ratio Decidendi
On the Issue of Mootness, Practical Relief, and Supervening Events: The Supreme Court held that the petition for nullity pending before the RTC Manila-Br. 6 assailing PRC Office Order No. 2016-56 was already moot. A case becomes moot when it ceases to present a justiciable controversy due to supervening events, rendering a declaration of no practical use or value. The Court reiterated that while generally declining jurisdiction over moot cases, it may decide them if there is a grave constitutional violation, exceptional circumstances with paramount public interest, a need for controlling principles, or if the issue is capable of repetition yet evading review. None of these exceptions were present in this case. The decision in the intra-corporate case by RTC Manila-Br. 24, which declared void the election of Engr. Conti as the 2016 PSME National President, effectively rendered PRC Office Order No. 2016-56, which recognized Engr. Conti for the purpose of issuing Certificates of Good Standing, ineffective and cancelled. Therefore, continuing with the nullity case would be pointless as no substantial relief could be granted. The Court cited Portugues v. Candaba to support the principle that no substantial relief can be obtained when the issue has become moot. The Court further explained that the respondent PSME would not obtain any actual or substantial relief by pursuing the declaration of nullity. The PRC Office Order No. 2016-56 was provisionally issued to ensure the renewal of Professional Identification Cards (PICs) would not be hampered by the leadership dispute, allowing the PSME to fulfill its mandate as the Accredited Professional Organization. The PRC's action was merely to administer and process renewals, not to decide on internal PSME leadership. The PRC itself had clarified in a letter dated February 5, 2016, that its recognition of Engr. Conti was "without prejudice" to the resolution of the pending intra-corporate case before RTC Manila-Br. 24. This signified the PRC's eventual adherence to the outcome of the intra-corporate case. Moreover, the PRC issued Resolution No. 107 Series of 2016 on August 5, 2016, suspending the requirement of the Certificate of Good Standing for PIC renewals, which practically rendered the assailed PRC Office Order ineffective. The Court emphasized that the PRC Office Order was not intended to declare Engr. Conti as the winner of the election, but rather to facilitate the administrative process of PIC renewals during a leadership conflict. The Court also noted that further supervening events had mooted the case. The 2016 National Officers' election had long taken place, and Engr. Conti was later appointed Chairman of the Professional Regulatory Board for Mechanical Engineers. Furthermore, since 2019, Engr. Jeffrey F. Singson has been the incumbent PSME National President. These developments, including the conclusion of the 2016 election and the installation of current officers, removed any actual controversies between the parties and rendered the resolution of the nullity case superfluous. The Court concluded that any decision on the nullity case would serve no useful purpose and could not be enforced, citing Philippine Sugar Institute v. Association of Philsugin Employees and Torm Shipping Philippines, Inc. v. Alacre.
Main Doctrine
A petition for declaration of nullity of a PRC Office Order recognizing a particular individual as president of a professional organization is rendered moot and academic when a subsequent decision in an intra-corporate case declares the election of that individual as president void, thereby rendering the PRC's recognition ineffective and without practical use or value.