GR 249353; (August, 2022) (Digest)
G.R. No. 249353. August 22, 2022
PHILIPPINE VETERANS BANK, PETITIONER, VS. COURT OF APPEALS, COLLEGE ASSURANCE PLAN PHILIPPINES, INC., AND MAMERTO A. MARCELO, JR., IN HIS CAPACITY AS THE REHABILITATION RECEIVER OF COLLEGE ASSURANCE PLAN PHILIPPINES, INC., RESPONDENTS.
FACTS
College Assurance Plan Philippines, Inc. (CAP), a pre-need company under rehabilitation, entered into a trust agreement with Philippine Veterans Bank (PVB) in 2002. In 2008, assets from other trustee banks were transferred to PVB. In 2013, CAP and PVB executed memoranda agreeing on trust fees for these transferred assets. In 2017, CAP’s Rehabilitation Receiver contested the fees being charged. The Regional Trial Court (RTC), acting as a Rehabilitation Court, issued a motu proprio Order in April 2017 directing PVB to refund over P50 million in excess trust fees and to adjust future fees according to the 2013 memoranda. PVB sought clarification, leading to an RTC Order in August 2018 affirming the refund directive and declaring the 2013 memoranda rates as applicable.
PVB filed a petition for certiorari under Rule 65 before the Court of Appeals (CA) assailing the August 2018 Order and praying for a Temporary Restraining Order or Writ of Preliminary Injunction (TRO/WPI) to halt the RTC’s directive. The CA, in a Resolution dated October 11, 2018, denied the application for TRO/WPI. It ruled that PVB failed to demonstrate a clear legal right necessitating protection or the existence of irreparable injury, noting any potential monetary loss was quantifiable and compensable. PVB’s motion for reconsideration was denied in July 2019, prompting this petition for certiorari.
ISSUE
Whether the Court of Appeals gravely abused its discretion in denying PVB’s application for a Temporary Restraining Order or Writ of Preliminary Injunction.
RULING
The Supreme Court dismissed the petition for being moot and academic. The Court emphasized that a case becomes moot when supervening events eliminate the justiciable controversy, rendering a ruling of no practical legal value. During the pendency of this petition before the Supreme Court, the CA promulgated a Decision on May 21, 2021, in the main case (CA-G.R. SP No. 157608) which dismissed PVB’s petition on the merits. The issue of the propriety of the TRO/WPI denial is merely an ancillary incident of that main petition. Since the CA had already resolved the principal case with finality, any ruling by the Supreme Court on the interlocutory matter of the TRO/WPI would be an academic exercise without practical effect. The Court declined to address the merits of the CA’s subsequent Decision, as it was not the subject of the instant appeal. Consequently, the petition was dismissed.