G.R. No. 254282 , September 14, 2021
Professional Regulation Commission, Petitioner, vs. Philippine Society of Mechanical Engineers (PSME), Respondent.

FACTS

The Philippine Society of Mechanical Engineers (PSME) held its 63rd National Convention and General Membership Meeting from October 21 to 25, 2015, which included the election of the 2016 PSME National Board of Directors. The PSME Commission on Elections (COMELEC) confirmed the election results on October 25, 2015. However, on October 26, 2015, Engr. Leandro A. Conti filed a letter-protest with the PSME-COMELEC alleging election irregularities. On November 22, 2015, the PSME-COMELEC issued an Omnibus Resolution annulling certain votes and declaring Engr. Conti’s group as the newly elected members of the 2016 Board. On November 25, 2015, the PSME-COMELEC conducted an election for the 2016 PSME National Officers, where Engr. Conti was elected National President. His group then filed an intra-corporate case (raffled to RTC Manila, Branch 24) seeking validation of the November 22 Omnibus Resolution and the November 25 election.
Simultaneously, on November 28, 2015, the 2015 PSME National Board proceeded with a scheduled Special Board Meeting and elected Engr. Murry F. Demdam as the 2016 PSME National President. On December 18, 2015, the Professional Regulation Commission (PRC), through Acting Chairperson Angeline Chua Chiaco, sent a letter acknowledging Engr. Conti as the 2016 National President. Subsequently, on February 10, 2016, the PRC issued Office Order No. 2016-56, recognizing Engr. Conti as the National President solely for the purpose of issuing Certificates of Good Standing required for the renewal of Professional Identification Cards.
On March 7, 2016, PSME, represented by Engr. Demdam, filed a petition for declaration of nullity of PRC Office Order No. 2016-56 before the RTC Manila, Branch 6. Meanwhile, on August 8, 2016, RTC Manila, Branch 24, decided the intra-corporate case, declaring valid the November 22, 2015 Omnibus Resolution on the Board of Directors but declaring void the November 25, 2015 election of the 2016 National Officers (including Engr. Conti’s election as President). A writ of execution was issued on August 23, 2016.
The PRC then filed an Omnibus Motion to Dismiss the nullity case before RTC Branch 6 on grounds of mootness and res judicata. On August 31, 2017, RTC Branch 6 granted the motion, ruling the petition was moot due to the Branch 24 decision and was barred by res judicata. The Court of Appeals reversed this dismissal on March 10, 2020, holding the case was not moot as the Branch 24 decision voided Engr. Conti’s election, and res judicata did not apply due to lack of identity of parties, causes of action, and reliefs prayed for. The CA remanded the case for resolution on the merits. The PRC’s motion for reconsideration was denied.

ISSUE

Has the petition for declaration of nullity of PRC Office Order No. 2016-56 pending before the RTC Manila-Br. 6 been rendered moot in view of the decision of the RTC Manila-Br. 24 in the intra-corporate case declaring void the election of Engr. Conti as 2016 PSME National President?

RULING

Yes, the petition has been rendered moot. The Supreme Court granted the PRC’s petition, reversed the Court of Appeals, and reinstated the RTC Branch 6’s dismissal of the nullity case.
A case becomes moot when it ceases to present a justiciable controversy because the issues have become academic or dead, or when a judgment can no longer provide any practical relief or be enforced. Here, PRC Office Order No. 2016-56 recognized Engr. Conti as National President solely for the purpose of signing Certificates of Good Standing for the 2016 renewal of Professional Identification Cards. This purpose was time-bound and specific to the 2016 renewal cycle. Furthermore, the PRC had already suspended the implementation of the Certificate of Good Standing requirement for mechanical engineers by August 5, 2016. The term of the contested 2016 PSME National Presidency had also long expired. Therefore, a judgment on the petition for nullity would no longer have any practical legal effect or be enforceable. The Court found it unnecessary to indulge in further academic discussion as the case was moot.