G.R. No. L-39008 October 28, 1988
PEDRO BAUTISTA, ET AL., plaintiffs-appellants, vs. THE MUNICIPALITY OF SAN JACINTO, ET AL., defendants-appellees.

FACTS

The plaintiffs-appellants are building contractors engaged in selling sand and gravel extracted from within the territorial limits of the Municipality of San Jacinto, Pangasinan. On September 8, 1960, the municipal council enacted Ordinance No. 8, imposing a tax of ten centavos (P0.10) per cubic meter of sand and gravel taken from the municipality. The appellants paid the tax under protest and subsequently filed an action to annul the ordinance. They argued it was unconstitutional and void on multiple grounds, including lack of municipal power to impose such a tax, that it constituted double taxation, and that it unreasonably restricted their freedom to use public roads.
The Court of First Instance of Pangasinan upheld the validity of the ordinance. The case was elevated to the Court of Appeals, which certified it to the Supreme Court as it involved pure questions of law. The core issue presented for resolution was the legality of the municipal ordinance imposing the extraction tax.

ISSUE

Whether the Supreme Court should rule on the validity of Municipal Ordinance No. 8, Series of 1960, of San Jacinto, Pangasinan.

RULING

The Supreme Court dismissed the appeal for being moot and academic. The legal logic is grounded in the principle that courts will not adjudicate cases where no actual, live controversy exists that would provide effective relief. The ordinance was enacted under the Local Autonomy Act ( Republic Act No. 2264 ). However, this law was subsequently superseded by the Local Tax Code ( Republic Act No. 2264 , as amended), which governed municipal taxing powers at the time of the Supreme Court’s review.
Crucially, Section 64-A of the Local Tax Code provided that all existing local tax ordinances would be deemed ipso facto nullified on June 30, 1974. By the time the Supreme Court rendered its decision in 1988, Ordinance No. 8 had long been automatically nullified by operation of this law. Therefore, any ruling on its validity in 1960 would be purely academic, serving no practical purpose or granting any useful relief to the parties. The Court consistently avoids rendering decisions on moot questions or abstract propositions. Since the legal framework that authorized the ordinance had changed and the ordinance itself was statutorily nullified, the issue was rendered moot, precluding a merits-based constitutional or statutory analysis.