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 M. Lu (petitioners). The complaints, filed with the Regional Trial Court (RTC) of Calamba City, Laguna, sought the nullification of a stockholder's meeting, the election of directors and officers, the general information sheet, and minutes of meetings for Remcor Industrial and Manufacturing Corporation (Remcor) and Soutech Development Corporation (Soutech). The respondents questioned the conduct of these meetings and elections held on March 4, 2014. Procedural History: The two complaints were raffled to Branch 34 of the RTC, presided over by Judge Maria Florencia Formes-Baculo. During the pendency of these cases, the respondents filed motions for the judge's inhibition, citing perceived bias and partiality due to alleged erroneous findings of fact, unfounded evidence, misapplication of law, and a lack of enthusiasm in resolving their motions. 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 orders and remanding the cases back to Branch 34. The petitioners then filed a motion for reconsideration, which the CA denied. This led to the present petition before the Supreme Court. The Petition: The petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court to assail the CA's Decision and Resolution. They argued that the CA petition was fatally defective for lacking certified true copies of the assailed orders, that mandamus rather than certiorari was the proper remedy, that the issue was rendered moot by a subsequent Consolidated Decision from RTC Branch 35 which resolved the main issues, and that Judge Formes-Baculo did not commit grave abuse of discretion in inhibiting herself. The Supreme Court granted the petition, finding that the Consolidated Decision of RTC Branch 35, which dismissed the respondents' complaints on the merits and upheld the validity of the contested meetings and elections, had rendered the CA petition moot and academic.
Issue(s)
Whether the Court of Appeals erred in reversing the voluntary inhibition of the Regional Trial Court Judge, and whether such issue is rendered moot by subsequent events. Whether the petition before the Court of Appeals was rendered moot and academic by the subsequent Consolidated Decision of the Regional Trial Court, Branch 35.
Ruling
The Supreme Court granted the petition. The Court of Appeals' Decision dated September 11, 2015, and Resolution dated December 14, 2015, in CA-G.R. SP No. 139683 were reversed and set aside. A new one was entered dismissing respondents' petition for certiorari and prohibition on the ground of mootness. The Court held that the Consolidated Decision of RTC Branch 35, which disposed of the main issues of the cases, rendered the CA petition moot and academic.
Ratio Decidendi
On the issue of the Court of Appeals' error in reversing the inhibition and its mootness: While the Court did not directly rule on the merits of the inhibition, its decision on mootness rendered this issue moot. The Court noted that the CA erred in reversing the inhibition orders without sufficient basis, as mere imputations of bias or partiality are not enough grounds for inhibition; concrete proof of specific acts is required. However, the primary basis for granting the petition was the supervening event that mooted the controversy before the CA. The Court emphasized that the CA should have dismissed the petition on mootness, thereby avoiding the need to pass upon the propriety of the inhibition itself. On the issue of mootness: The Court held that the promulgation of the Consolidated Decision by RTC Branch 35 on July 13, 2015, which dismissed the respondents' complaints on the merits and upheld the validity of the contested stockholders' meetings and elections, rendered the petition for certiorari and prohibition before the Court of Appeals moot and academic. This supervening event meant that the appellate court should have dismissed the petition on the ground of mootness, as a declaration on the inhibition issue would no longer have any practical use or value. The Court reiterated the settled rule that the mere pendency of a special civil action for certiorari does not automatically interrupt the proceedings in the lower court, and that jurisdiction over the main actions attached to the RTC, not its specific branches, to the exclusion of others. The subsequent resolution by the CA, ordering the return of records for speedy trial, was rendered nugatory by the fact that Branch 35 had already accomplished the resolution of the main actions.
Main Doctrine
The Supreme Court granted the petition, reversing the Court of Appeals' decision and resolution. The Court held that the consolidated decision rendered by Branch 35 of the Regional Trial Court of Calamba City, which disposed of the main issues in SEC Case Nos. 99-2014-C and 100-2014-C, rendered the petition for certiorari and prohibition filed before the Court of Appeals moot and academic. Consequently, the appellate court should have dismissed the petition on the ground of mootness instead of ruling on the merits of the inhibition issue.