G.R. No. 161405 July 21, 2006
PHILIPPINE VETERANS AFFAIRS OFFICE, et al., petitioners, vs. YOLANDA ARQUERO, et al., respondents.

FACTS

Petitioner Philippine Veterans Affairs Office (PVAO) administers the Libingan ng mga Bayani, a national shrine reserved under Proclamation No. 208. Respondents, comprising about 400 families, are residents of Sitio Masigasig within the reservation area, having occupied the land since 1986. In 2001, petitioners, as members of a Task Force, commenced demolition operations. Respondents filed a petition for prohibition with the Regional Trial Court (RTC) to enjoin the demolition, which the RTC denied. The Court of Appeals reversed the RTC, permanently enjoining petitioners from undertaking eviction and demolition operations against respondents for violating Republic Act No. 7279 (Urban Development and Housing Act).
During the pendency of the Supreme Court petition, a supervening event occurred. On May 7, 2005, a fire destroyed 300 houses in Sitio Masigasig. When respondents attempted to repair their dwellings, petitioners prevented them and installed barbed wires around the area, asserting ownership and the land’s reservation for the Libingan ng mga Bayani.

ISSUE

Whether the permanent injunction issued by the Court of Appeals has been rendered moot and academic by the fire that destroyed the respondents’ houses.

RULING

Yes, the injunction is moot. The Supreme Court granted the petition and set aside the Decision of the Court of Appeals. The legal logic is anchored on the effect of a supervening event that fundamentally alters the controversy’s nature. The Court of Appeals’ injunctive writ was issued specifically to prevent the Task Force from undertaking eviction and demolition operations against the existing structures of the residents. The fire, an act of force majeure, destroyed those very structures. Consequently, the object of the injunction—to prohibit the demolition of houses—ceased to exist. There were no longer any houses to demolish.
The Court rejected respondents’ argument that the injunction intended to maintain the status quo ante, thus allowing them to rebuild. The writ’s plain import was limited to prohibiting active demolition by the petitioners; it did not confer a positive right to rebuild or prohibit the petitioners from securing the area, which is government property reserved for a national shrine. The installation of barbed wires, as an act of ownership over titled government land, is not equivalent to the eviction or demolition operations covered by the injunction. Therefore, the case was rendered moot, and no justiciable controversy remained for resolution.