G.R. No. L-38705, L-44358, L-44727, L-45043. July 25, 1979.
CARLITO GAÑA, ET AL., petitioners, vs. COURT OF APPEALS, ET AL., respondents. (Consolidated Cases).

FACTS

The consolidated cases originated from CAR Case No. 2546-T ’73 filed by Carlito Gaña, et al., before the Court of Agrarian Relations (CAR) in Tarlac. Petitioners alleged they were agricultural share tenants of the private respondents and sought a change to a leasehold system under agrarian laws, along with protection from dispossession. On June 1, 1973, they filed a motion for an interlocutory order to restrain the landowners from ejecting them. The landowners opposed and filed a counter-motion to restrain the tenants. On July 2, 1973, the CAR Judge denied the tenants’ motion and granted the landowners’ counter-motion. The tenants’ motion for reconsideration was denied.
The tenants then filed a petition for review with the Court of Appeals (CA-G.R. No. SP-02394-R) seeking to annul the CAR orders. The CA initially issued a restraining order but later lifted it and, after a hearing where only the landowners’ counsel appeared, dismissed the petition on October 23, 1973. A motion for reconsideration was denied. Gaña, et al., subsequently elevated the matter to the Supreme Court via a petition for certiorari, docketed as G.R. No. L-38705. While this petition was pending, the Supreme Court advised the CAR Judge to continue hearing the main agrarian case. The CAR eventually rendered a decision on the merits, which became final and executory. Related petitions, G.R. No. L-44358 (also by Gaña, et al.), G.R. No. L-44727 (by Benigno Castro), and G.R. No. L-45043 (by Candido Baron), arising from interconnected proceedings, were likewise elevated to the Supreme Court.

ISSUE

The primary issue in G.R. No. L-38705 was whether the petition for certiorari assailing the Court of Appeals’ dismissal of the challenge to the CAR’s interlocutory orders had been rendered moot and academic by subsequent events, particularly the final judgment in the main agrarian case.

RULING

The Supreme Court dismissed G.R. No. L-38705 as moot and academic. The legal logic is grounded in the principle that courts will not determine a question that no longer presents a justiciable controversy because its resolution will have no practical effect. The petition sought to nullify the CAR’s July 1973 interlocutory orders which denied injunctive relief to the tenant-petitioners. However, while G.R. No. L-38705 was pending before the Supreme Court, the CAR proceeded, as advised, to hear the main case (CAR Case No. 2546-T ’73) on its merits and rendered a final decision. That decision on the merits superseded the preliminary interlocutory orders. Since a final judgment on the substantive rights of the parties had been entered, any ruling on the propriety of the preliminary orders would be an academic exercise without practical legal consequence. The Court also noted that the related petition, G.R. No. L-44358, had been denied with finality, reinforcing the finality of the proceedings. Consequently, the issues in G.R. No. L-38705 were extinguished by the conclusive judgment in the principal action. The Court disposed of the other consolidated petitions accordingly, closing G.R. No. L-45043 and returning G.R. No. L-44727 to the First Division for decision.