G.R. No. L-34725-30 January 17, 1974
MANUEL B. IMBONG and MIGUEL M. MENDOZA, doing business under the name and style “LA SUERTE TAXI, INC.”, petitioners, vs. OIL INDUSTRY COMMISSION, ESSO PHILIPPINES, INC., MOBIL OIL PHILIPPINES, INC., CALTEX PHILIPPINES, INC., GETTY OIL (PHILIPPINES), INC., SHELL PHILIPPINES, INC., FILOIL REFINERY CORPORATION and FILOIL MARKETING CORPORATION, respondents.

FACTS

Petitioners, operators of a taxi company, filed an opposition to the separate applications for price increases filed by various oil companies with the respondent Oil Industry Commission (OIC). They argued the applications lacked necessary supporting data on asset values, production costs, and profits. To substantiate their opposition, petitioners filed a motion with the OIC to be allowed to inspect the books of account and other financial records of the respondent oil companies from 1969 onward.
The OIC denied petitioners’ motion for inspection, as well as a subsequent motion for reconsideration. Consequently, petitioners instituted these consolidated actions for mandamus to compel the OIC and the oil companies to grant them access to the requested documents. Their core legal argument was that the denial of such access constituted a violation of procedural due process, as it rendered their right to a meaningful opposition nugatory, contravening the administrative due process requirements established in Ang Tibay v. CIR.

ISSUE

Whether the petitions for mandamus to compel the inspection of the oil companies’ books of account have been rendered moot and academic.

RULING

Yes, the petitions have been rendered moot and academic. The Supreme Court dismissed the petitions based on a manifestation filed by the petitioners themselves. While the case was pending before the Court, the OIC proceeded with the hearings on the price increase applications. Other oppositors presented their evidence, and on September 18, 1972, the OIC granted the price increases. This OIC decision was subsequently challenged before the Supreme Court in a separate case, Ozaeta v. Oil Industry Commission.
Crucially, on December 21, 1973, petitioners filed a manifestation acknowledging that global posted prices for petroleum had indeed increased. They stated they had no objection to the dismissal of their mandamus petitions, though without foreclosing their right to raise the same issues in the future. The Court found this manifestation well-grounded. The primary relief sought—access to records to oppose the 1971 applications—had been overtaken by events, specifically the OIC’s grant of the increases and the subsequent global market developments. The resolution of the mandamus petitions would no longer have any practical legal effect on the original price increase applications. Therefore, the case was moot. The Court granted the dismissal as prayed for, explicitly noting that such dismissal did not preclude petitioners from raising the significant due process and right-to-information issues in an appropriate future case.