G.R. No. L-45074. April 30, 1987.
THE GOVERNMENT SERVICE INSURANCE SYSTEM, ROMAN A. CRUZ, JR., SHERIFF OF MANILA and SHERIFF OF QUEZON CITY, petitioners, vs. THE HONORABLE COURT OF APPEALS, HONORABLE AUGUSTO L. VALENCIA, (As Judge of the Court of First Instance of Rizal, Branch XXXI) and FELIPE T. ANG, respondents.

FACTS

Private respondent Felipe T. Ang obtained several loans from petitioner GSIS from 1958 to 1965, secured by real estate mortgages, to construct a building. By 1965, his indebtedness reached P7,175,000. A subsequent application for a re-financing loan was disapproved by the GSIS Board in 1967 based on its policy. Due to arrears, GSIS initiated foreclosure proceedings in 1971. In response, Ang filed a complaint in 1972 before the Court of First Instance of Rizal seeking to permanently restrain the foreclosure, obtain an updated statement of accounts, and secure a loan extension. The trial court initially issued a writ of preliminary injunction but later dissolved it.
After the dissolution of the injunction, GSIS proceeded with the foreclosure, purchased the properties at public auction in March 1974, and corresponding certificates of sale were issued. GSIS then moved to dismiss the still-pending main complaint in the trial court, arguing the foreclosure rendered the case moot. The trial court denied the motion, ruling that the dissolution of the ancillary writ of preliminary injunction did not resolve the main cause of action. GSIS elevated the matter to the Court of Appeals via certiorari, which dismissed the petition. Hence, this petition for review.

ISSUE

Whether the trial court committed grave abuse of discretion in refusing to dismiss the main complaint after the foreclosure sale had been conducted.

RULING

The Supreme Court granted the petition and declared the case moot and academic. The legal logic is anchored on the doctrine of mootness, which dictates that courts will not determine cases where no actual controversy exists or where the issues have been rendered academic by subsequent events. The Court noted that this case is intertwined with a prior related case, G.R. No. L-41811 (GSIS vs. Court of Appeals, et al.), involving the same parties and subject matter. In that decision, promulgated on November 10, 1986, the Supreme Court had already definitively ruled on the core issues, reinstating a writ of possession in favor of GSIS after the redemption period lapsed and titles were transferred.
Since the November 1986 decision in G.R. No. L-41811 conclusively resolved the fundamental disputes between the parties regarding the foreclosure and GSIS’s rights as purchaser, any further proceedings in the trial court on Ang’s complaint would serve no practical purpose. The foreclosure was completed, the properties were sold, and the redemption period expired without redemption. Therefore, the pending action before the trial court, which sought essentially to prevent or challenge that foreclosure, no longer presented a justiciable controversy. The Supreme Court held that the trial court should have dismissed the case as moot following the foreclosure and the final ruling in the related case. Consequently, the Regional Trial Court was ordered to terminate the proceedings.