GR L 4209; (April, 1951) (Digest)
G.R. No. L-4209; April 18, 1951
EDWARD C. GARRON, FELICIANO Y. CASERO, and GENEROSO ENCARNACION, petitioners, vs. HON. FRANCISCO ARCA, Judge of the Court of First Instance of Pampanga, Fifth Judicial District, and DOMINGO PINEDA, respondents.
FACTS
Upon application of Captain G. I. Purington, Assistant Provost Marshal of Clark Field, a search warrant was issued by the Justice of the Peace Court of Angeles, Pampanga, against respondent Domingo Pineda concerning auto spare parts. The warrant was served by PC Sergeant Generoso Encarnacion, assisted by Edward C. Garron and Feliciano Y. Casero as agents of the Provost Marshal, resulting in the seizure of auto spare parts belonging to Pineda. Pineda contested the legality of the warrant and filed an action for replevin against the agents (petitioners) in the Court of First Instance of Pampanga. The petitioners moved to dismiss the replevin case on grounds of lack of jurisdiction over their persons and the subject matter, among others. The court denied the motion and a subsequent motion for reconsideration, prompting the petitioners to file this petition for certiorari. Meanwhile, the petitioners caused a theft charge to be filed against Pineda involving the same articles, which was later dismissed for lack of evidence, and the seized articles were ordered returned to Pineda. Consequently, Pineda moved for the dismissal of the replevin case, which was granted by the court.
ISSUE
Whether the petition for certiorari should be decided on the merits despite the dismissal of the underlying replevin case, which rendered the controversy moot.
RULING
The Supreme Court dismissed the petition as moot and academic. The Court held that its duty is to decide actual controversies, not hypothetical cases. The main purpose of the petition—to have the replevin case dismissed for lack of jurisdiction—had already been accomplished by its dismissal, albeit on different grounds. Since the petitioners did not appeal the order dismissing the replevin case, that order became final, and the replevin case ceased to have legal existence. As the certiorari case was an outgrowth of the now-nonexistent main case, there was no point in continuing with it. The Court emphasized the rule that courts decline jurisdiction over moot cases where no actual interests are involved. The dismissal was without prejudice to the petitioners taking proper action regarding the seized articles.