GR L 57627; (May, 1985) (Digest)
G.R. Nos. L-57627 & 58966 May 31, 1985
ROLANDO TINIO, petitioner, vs. JUDGE JOSE P. CASTRO, Court of First Instance of Quezon City, and ANNA H. QUINTAL, respondents.
FACTS
This case originated from an ejectment proceeding. Respondent Anna H. Quintal, the owner of a property at 79 C. Salvador Street, Loyola Heights, Quezon City, filed a case to eject her tenant, petitioner Rolando Tinio. The City Court of Quezon City rendered a judgment on November 14, 1979, ordering Tinio’s ejectment from the premises.
Tinio subsequently elevated the matter to the Supreme Court through two separate petitions. In the first petition ( G.R. No. 57627 ), filed on August 6, 1981, Tinio sought to enjoin the sheriff of Quezon City from executing the city court’s ejectment judgment. In his second petition (G.R. No. 58966), filed on November 25, 1981, he directly prayed for the judgment itself to be set aside. The cases were consolidated and submitted for the Court’s decision.
ISSUE
The primary issue became whether the petitions for certiorari and prohibition, seeking to prevent or nullify the execution of the ejectment judgment, retained any justiciable controversy for the Supreme Court to resolve.
RULING
The Supreme Court dismissed the consolidated petitions as moot and academic. The legal logic for dismissal is grounded in the principle that courts will not adjudicate cases where no actual, substantial, and live controversy exists between the parties. A case becomes moot when its resolution can no longer provide any practical legal effect or tangible relief to the prevailing party.
Here, the core relief sought by Tinio in both petitions was to maintain his possession of the leased premises by stopping the execution of the ejectment order. However, during the pendency of the Supreme Court proceedings, the parties filed a joint motion dated May 17, 1985. They informed the Court that Tinio had already voluntarily vacated the subject property and that physical possession had been delivered to Quintal. This development completely extinguished the central dispute. Any ruling from the Court on the validity of the execution or the underlying judgment would be purely academic, as the act sought to be prevented—Tinio’s eviction—had already been consummated. Consequently, with the primary object of the litigation having been realized independently of judicial intervention, the Court had no remaining issue to decide and dismissed the cases without costs.