G.R. Nos. L-44233, L-44234 and L-44235. May 15, 1981.
Jose Legarda, petitioner, vs. Court of Appeals and Its Presiding Justice, respondents.

FACTS

Jose Legarda filed a mandamus action on July 29, 1976 to compel the Court of Appeals or its Presiding Justice to sign and issue certifications of affirmance for three appealed orders from a testamentary proceeding. The appeals (CA-G.R. Nos. 43480-R, 51222-R, and 53355-R) were submitted for decision on April 5, 1973, July 19, 1974, and July 5, 1974, respectively. Legarda contended that these cases were not decided within the twelve-month period mandated by Section 11, Article X of the 1973 Constitution, thereby entitling him to certifications that the lower court’s orders were deemed affirmed.
During the pendency of the petition, a supervening event occurred: Legarda was served a copy of the decision in CA-G.R. No. 43480-R on August 2, 1976. Subsequently, in a manifestation dated December 5, 1980, Legarda informed the Supreme Court that the two remaining cases (CA-G.R. Nos. 51222-R and 53355-R) had also been decided by the Court of Appeals on October 30 and November 12, 1980, respectively. He thus conceded that his petition had become moot and academic.

ISSUE

Whether the petition for mandamus to compel the issuance of certifications of affirmance due to the Court of Appeals’ alleged failure to decide within the constitutional twelve-month period has been rendered moot and academic.

RULING

The Supreme Court dismissed the petition as moot and academic. The legal logic is grounded in the principle that courts will not determine cases where no actual controversy exists or where the issues have been resolved by subsequent events. The core objective of Legarda’s mandamus action was to secure judicial decisions or their deemed affirmances. This objective was overtaken by the Court of Appeals’ actual rendition of decisions in all three cases. Specifically, CA-G.R. No. 43480-R was decided in 1976, and the two other cases were decided in 1980. With the appellate court having performed the very act sought to be compelled—the rendering of decisions—there remained no live grievance or effective relief for the Supreme Court to grant. The dismissal on mootness grounds renders unnecessary any adjudication on the substantive question of whether the constitutional twelve-month period for decision is mandatory or merely directory, or whether the failure to decide was due to an inability to secure the necessary vote, as raised by some heirs. The case was therefore ordered closed.