Social Security System v. National Grid Corporation
REITERATIONFacts
The Antecedents: The National Grid Corporation of the Philippines (NGCP), a private entity franchised to operate and maintain the nationwide transmission system, sought to expropriate a 46,218 square meter parcel of land owned by the Republic of the Philippines and occupied by the Social Security System (SSS). NGCP claimed the property was necessary for its Pasay 230kV Substation Project, intended to meet the rising electricity demand in the Greater Manila Area. Procedural History: NGCP filed a complaint for expropriation against SSS, later amending it to exclude other defendants. NGCP moved to deposit PHP 1,460,928,000.00, based on the BIR zonal valuation, and requested a writ of possession. The Regional Trial Court (RTC) of Pasay City, Branch 108, initially ordered the deposit and subsequently granted NGCP's motion for a writ of possession in its Orders dated March 2, 2017, and April 24, 2017, despite SSS's opposition. SSS then filed a special civil action for certiorari with the Supreme Court. The Petition: SSS filed a petition for certiorari under Rule 65 of the Rules of Court, assailing the RTC's Orders. SSS argued that the RTC gravely abused its discretion, contending that RA 10752, which facilitates the acquisition of right-of-way for national government infrastructure projects, does not apply to private corporations like NGCP. SSS also questioned NGCP's authority to initiate expropriation proceedings without proper deputation and argued that NGCP could not expropriate property already devoted to public use. Furthermore, SSS claimed there was no genuine necessity for the expropriation as NGCP had not offered to purchase the property. SSS sought a status quo ante order.
Issue(s)
Whether the Petition for Certiorari may be dismissed on the ground of mootness. Whether the RTC gravely abused its discretion in issuing the writ of possession.
Ruling
The Petition is DISMISSED for being moot and academic.
Ratio Decidendi
On the issue of mootness: The Court held that the Petition for Certiorari must be dismissed on the ground of mootness. An order issuing a writ of possession in an expropriation case is an interlocutory order, which is dependent on and incidental to the main petition for expropriation. In this case, the main action for expropriation was dismissed by the RTC upon NGCP's motion to withdraw its complaint and release of the provisional deposits. The Court reiterated that where the main action is already dismissed or disposed of, resolving a petition for certiorari assailing interlocutory orders issued in that case would be manifestly pointless. Such a situation renders the adjudication of the case or a declaration on the issue of no practical value or use, as there is no actual substantial relief that a petitioner would be entitled to. The Court generally declines jurisdiction over such cases or dismisses them on the ground of mootness because the judgment will not serve any useful purpose or have any practical legal effect as it cannot be enforced. The Court found no exceptions that would enable it to resolve the issues despite their mootness. The provided text does not contain a ratio decidendi that directly addresses whether the RTC gravely abused its discretion in issuing the writ of possession. Therefore, no corresponding ratio is available for this issue.
Main Doctrine
A petition for certiorari assailing an interlocutory order, such as a writ of possession in an expropriation case, becomes moot and academic when the main action for expropriation is dismissed.