Philippine Veterans Bank v. Court of Appeals
REITERATIONFacts
The Antecedents: College Assurance Plan Philippines, Inc. (CAP) entered into a trust agreement with Philippine Veterans Bank (PVB) in 2002. In 2005, CAP filed for corporate rehabilitation. In 2008, PVB received assets held in trust by other banks for CAP. In 2013, CAP and PVB agreed on trust fees to be charged on the transferred assets. In 2017, CAP's Rehabilitation Receiver expressed reservations on PVB's trust fees. The Regional Trial Court (RTC) issued a motu proprio Order directing PVB to refund excess trust fees collected and to adjust future fees according to the 2013 memoranda. Procedural History: PVB sought clarification from the RTC regarding the April 21, 2017 Order. The RTC clarified that the order directed PVB to update adjustments based on the trust fees stipulated in the September 22, 2013 trust agreement. PVB pointed out an alleged clerical error in the RTC's January 10, 2018 Order, suggesting the applicable agreement date was September 27, 2002, not September 22, 2013. CAP argued that the RTC intended the October 22, 2013 memoranda to prevail. In an August 9, 2018 Order, the RTC affirmed its previous order for PVB to refund P50,639,642.94 to CAP and clarified that the date mentioned referred to the 2013 memoranda. Aggrieved, PVB filed a petition for certiorari with the Court of Appeals (CA) seeking a temporary restraining order (TRO) and writ of preliminary injunction (WPI). The Petition: The CA denied PVB's prayer for TRO/WPI, stating PVB failed to show a right needing protection, invasion thereof, or irreparable damage. The CA noted that any damage would be compensable. PVB's motion for reconsideration was denied. Hence, PVB filed the instant petition for certiorari before the Supreme Court, assailing the CA's denial of the TRO/WPI.
Issue(s)
Whether the Court of Appeals gravely abused its discretion when it denied Philippine Veterans Bank's prayer for a temporary restraining order/writ of preliminary injunction.
Ruling
The petition is dismissed for being moot and academic.
Ratio Decidendi
On the Issue of Grave Abuse of Discretion in Denying the TRO/WPI: The Supreme Court dismissed the petition for being moot and academic. The Court explained that a case becomes moot and academic when supervening events render its adjudication without practical value or use, meaning no actual substantial relief can be granted to the petitioner. In this instance, the CA promulgated a Decision dated May 21, 2021, in CA-G.R. SP No. 157608, which dismissed PVB's petition before it on the merits. The propriety of the CA's denial of the TRO/WPI, which was the subject of the present petition, was merely an incident of the main case before the CA. Since the main case has already been resolved on its merits by the CA, any ruling on the present petition would be a mere academic exercise with no practical legal effect. The Court emphasized that it would be premature to tackle the merits of the CA's recent Decision as it was not the matter appealed before the Supreme Court. Therefore, the petition was dismissed on the ground of mootness.
Main Doctrine
A case becomes moot and academic when supervening events render the adjudication of the issue without practical value or use, as no actual substantial relief can be granted.