G.R. No. 137881. August 19, 2005. ISAAC DELGADO and FERNANDO DELGADO, Petitioners, vs. COURT OF APPEALS, ZACARIAS LIMPANGOG, REMEGIO LAGUNA, SANTIAGO BALORO, CAMILO EVANGELISTA, NEMESIO AMORES and RUSTICO RUIZO, Respondents.
FACTS

Private respondents filed a complaint for reinstatement with damages before the DAR Adjudication Board (PARAB), claiming they were tenants of petitioners’ riceland since 1962 and were issued Certificates of Land Transfer and later Emancipation Patents under P.D. No. 27. Petitioners opposed, alleging abandonment by the tenants and that the action was barred by res judicata due to a prior dismissal by the RTC. The PARAB initially favored private respondents but later modified its decision, finding abandonment. The DARAB reversed, reinstating the original PARAB decision. Petitioners filed a petition for review with the Court of Appeals, which was dismissed outright for procedural deficiencies including an improper verification and lack of required attachments.

ISSUE

Whether the Supreme Court should grant the motion for reconsideration and reverse its prior decision affirming the CA’s dismissal.

RULING

The Supreme Court granted the motion for reconsideration but ultimately dismissed the entire petition for being moot and academic. The legal logic proceeds from the principle that courts will not adjudicate cases where no actual controversy exists. During the pendency of the motion, a supervening event occurred: the DARAB issued a final and executory Decision on December 12, 2003, in a separate cancellation case (DARAB Case No. 8958), which definitively ruled that the Emancipation Patents issued to private respondents were null and void. This subsequent decision rendered the core issue in the present case—the validity of the tenants’ rights and the reinstatement order—entirely academic. There was no longer any substantial relief that could be granted, as the DARAB’s final resolution had already extinguished the rights private respondents sought to enforce. The Court emphasized its policy of declining jurisdiction over moot cases. Consequently, the previous decision was set aside, and the petition was dismissed. Both parties were admonished for failing to inform the Court of this decisive supervening judgment.