G.R. No. 187256 ; February 23, 2011
CONSTANCIO F. MENDOZA and SANGGUNIANG BARANGAY OF BALATASAN, BULALACAO, ORIENTAL MINDORO, Petitioners, vs. MAYOR ENRILO VILLAS and BRGY. KAGAWAD LIWANAG HERATO and MARLON DE CASTRO, Manager, Pinamalayan Branch, Land Bank of the Philippines, Respondents.

FACTS

In the 2007 barangay elections, Constancio F. Mendoza obtained the highest votes for Punong Barangay of Barangay Balatasan, Bulalacao, Oriental Mindoro, and was proclaimed by the COMELEC. The losing candidate filed a quo warranto petition with the Municipal Trial Court (MTC), which disqualified Mendoza and declared that Liwanag Herato, the highest-ranking Barangay Kagawad, was entitled to succeed him. Mendoza appealed this MTC Decision to the COMELEC. Despite the pending appeal and without a writ of execution, Mayor Enrilo Villas administered the oath to Herato and issued a memorandum directing municipal departments to recognize Herato. Mendoza sought advice from the DILG, which informed Villas that Mendoza should occupy the post pending appeal. Nevertheless, the Municipal Administrator, by Villas’s authority, wrote to Land Bank of the Philippines (LBP) Manager Marlon de Castro requesting that transactions by Mendoza not be honored, dismissing the DILG letter as merely advisory. Consequently, de Castro advised both parties that LBP would not honor any transactions regarding the barangay’s accounts. Petitioners then filed a Petition for Mandamus with Damages and Prayer for a Writ of Preliminary Mandatory Injunction (Special Civil Action No. 08-10) with the RTC, praying that LBP be directed to release the barangay funds to them. Respondents filed answers and a motion to dismiss, attaching a COMELEC Resolution dated September 8, 2008, from a separate disqualification case (COMELEC Case No. SPA-07-243-BRGY) which disqualified Mendoza for having served three consecutive terms. Mendoza presented a COMELEC Certification dated February 27, 2009, stating that said COMELEC case was still pending. The DILG also issued another opinion reiterating that the MTC Decision was not yet final. The RTC issued an Order dated February 2, 2009, dismissing the mandamus petition based on the COMELEC Resolution disqualifying Mendoza, and denied the motion for reconsideration in an Order dated March 17, 2009. Petitioners filed a direct recourse to the Supreme Court.

ISSUE

Whether the Supreme Court should grant the petition to set aside the RTC Orders and direct the continuation of the mandamus proceedings.

RULING

The Supreme Court DENIED the petition. The Court treated the petition as one filed under Rule 45, as it raised only questions of law. However, the Court found the case had been rendered moot and academic by a supervening event: the conduct of the 2010 barangay elections. Mendoza’s term of office had expired with those elections. Consequently, whatever judgment the Court could render would no longer have any practical legal effect or be enforceable. The mandamus action (Special Civil Action No. 08-10) could no longer prosper, and Mendoza no longer had legal standing to pursue the case. The Court emphasized that it generally declines jurisdiction over moot cases. Therefore, the petition was dismissed.