G.R. No. L-28096. June 28, 1974.
Abelardo Subido, in his capacity as Commissioner of Civil Service, petitioner, vs. Jovito Salonga, in his capacity as Chairman, Senate Committee on Civil Service, and Francisco Rodrigo, in his capacity as Chairman, Ad Hoc Blue Ribbon Committee, Senate, respondents.

FACTS

Petitioner Abelardo Subido, the Commissioner of Civil Service, filed a special civil action for prohibition and mandamus with preliminary injunction. He sought to enjoin the respondent Senate Committee Chairmen, Jovito Salonga and Francisco Rodrigo, from continuing their investigation into administrative charges filed against him by Atty. Faustino F. Tugade. Concurrently, an Investigating Committee created by the President of the Philippines, who held direct disciplinary jurisdiction over the Civil Service Commissioner, was already hearing the same charges. Subido argued that the Senate committees were improperly conducting a parallel investigation and requested the Court to order the return of records taken by them.
The Court gave due course to the petition in October 1967. However, before the case could be resolved on its merits, significant changes occurred. Petitioner Subido ceased to hold the office of Commissioner of Civil Service. Furthermore, with the effectivity of the 1973 Constitution on January 17, 1973, the Senate of the Philippines was abolished, and legislative power was vested in a unicameral National Assembly. Consequently, the official positions held by respondents Salonga and Rodrigo also ceased to exist.

ISSUE

Whether the petition, which originally questioned the authority of the Senate committees to investigate the Civil Service Commissioner, remains a justiciable controversy.

RULING

The Supreme Court dismissed the petition for being moot and academic. The core legal principle applied is that courts exist to adjudicate actual, live controversies, not to resolve hypothetical questions or issue advisory opinions. A justiciable controversy requires a definite and concrete dispute touching the legal relations of parties with adverse legal interests, admitting of specific and conclusive relief.
The Court held that the change in circumstances had rendered the original controversy nonexistent. Since petitioner was no longer the Commissioner of Civil Service and the respondent Senate committees (and the Senate itself) were abolished by the 1973 Constitution, any judgment on the merits would be ineffectual. A ruling on whether the Senate could properly investigate a sitting Commissioner while a presidential committee was doing the same could no longer provide any practical legal effect or relief to the parties involved. Therefore, the case was dismissed for mootness without pronouncement as to costs.