Philippine Ass'n of Mechanical & Electrical Engineers v. Cuenco
REITERATIONFacts
The Antecedents: In 1939, Manuel I. Felizardo, Andres Borromeo, and Florentino Reyes constituted the Board of Mechanical Engineering. Alberto Muscat, Norberto Capay, and others petitioned the Board to be registered as professional mechanical engineers without examination, alleging they possessed the qualifications under Section 44(a) of Commonwealth Act No. 294, as amended by Commonwealth Act No. 481. The Board denied their petition on October 17, 1939, finding the applicants lacked the required qualifications. Procedural History: On November 17, 1939, the Board submitted its resolution to the Secretary of Public Works and Communications, M. Jesus Cuenco. Following a conference with the Secretary of Justice, who advises the Board, Secretary Cuenco instructed the Board to reconsider its decision and issue the certificates of registration. On November 24, 1939, the Board resolved that although, in their opinion, the applicants did not meet the legal qualifications, they would submit the names of Muscat and Capay to the Secretary of Public Works for registration, in deference to the Secretary of Justice's opinion. The Petition: The Philippine Association of Mechanical and Electrical Engineers filed a petition for certiorari with the Supreme Court against Secretary M. Jesus Cuenco and the members of the Board, alleging that the respondents acted without jurisdiction and with grave abuse of discretion in submitting the names for registration without examination. They prayed for a declaration that the respondents acted without jurisdiction and with grave abuse of discretion.
Issue(s)
Whether the respondents, the Secretary of Public Works and Communications and the Board of Mechanical Engineering, acted without jurisdiction and with grave abuse of discretion in submitting the names of Alberto Muscat and Norberto Capay for registration as professional mechanical engineers without prior examination, despite the Board's opinion that the applicants lacked the required qualifications. Whether the case has become moot and academic due to supervening events.
Ruling
The Supreme Court dismissed the petition without special pronouncement as to costs. The Court found that the case had become moot and academic due to supervening events.
Ratio Decidendi
On Whether the respondents acted without jurisdiction and with grave abuse of discretion: The Court noted that the original respondents, Manuel I. Felizardo and Florentino Reyes, were no longer members of the Board. Their successors, Clemente Hidalgo and Felipe A. Roman, along with the remaining member Andres Borromeo, had resolved to conform to the interpretation of the law given by the Secretary of Justice and the Secretary of Public Works and Communications. This action by the current members of the Board, in unconditionally adopting the opinion of the Secretary of Justice, removed the basis for the petition for certiorari against them. The Court also observed that the original Board members, while expressing their personal opinion that the applicants lacked the qualifications, ultimately submitted the names for registration out of deference to the Secretary of Justice's opinion. However, the subsequent unconditional adoption of this interpretation by the new Board rendered the issue of abuse of discretion moot as to the current composition of the Board. On Whether the case has become moot and academic: The Court found that the case had indeed become moot and academic. This was primarily due to the fact that two of the original members of the Board of Examiners, Manuel I. Felizardo and Florentino Reyes, had ceased to be members. They were replaced by Clemente Hidalgo and Felipe A. Roman. Furthermore, the new composition of the Board, including the new members and the continuing member Andres Borromeo, had resolved to conform to the interpretation of the law as given by the Secretary of Justice and the Secretary of Public Works and Communications. This supervening event meant that the controversy as originally presented to the Court had been resolved by the actions of the current Board, rendering a decision on the merits of the petition unnecessary.
Main Doctrine
The Supreme Court reiterated that a case becomes moot and academic when the issue presented has already been resolved or has ceased to exist. This principle applies when the parties involved in the controversy have changed, and the current parties have adopted the challenged action, thereby rendering a judicial determination of the original dispute unnecessary. Consequently, the Court may dismiss the case without special pronouncement as to costs.