GR 31506 8; (December, 1978) (Digest)

G.R. No. L-31506 December 29, 1978
JOSE R. OLIVEROS, in his capacity as Municipal Mayor of Antipolo, Rizal, petitioner, vs. HON. BENJAMIN H. AQUINO, Judge, Court of First Instance of Rizal, JOSE S. OLIVEROS, OSCAR OLIVEROS, JOSE SUMULONG, JOSE PARANAS, ELPIDIO HERRERA, BENJAMIN ARAQUEL, GREGORIO CARIGMA, FEDERICO GARCIA, and ANTONIO SANTOS, respondents.

FACTS

This case originated from a 1969 shooting incident in Antipolo, Rizal, which resulted in deaths and injuries. Following the incident, administrative and criminal charges were filed against the Antipolo Chief of Police, Jose S. Oliveros, and several policemen. Petitioner Mayor Jose R. Oliveros subsequently ordered the preventive suspension of these police officers. In response, the suspended officers filed three separate civil cases in the Court of First Instance of Rizal, presided over by respondent Judge Benjamin H. Aquino, to challenge the mayor’s disciplinary authority and a subsequent Constabulary takeover of police functions. Judge Aquino issued various restraining and injunctive orders against the mayor’s actions in these cases.
The mayor then filed the instant petition for certiorari and prohibition with the Supreme Court, assailing Judge Aquino’s orders. This Court issued a restraining order in 1970, which effectively halted the enforcement of the lower court’s injunctions. Subsequently, significant supervening events occurred: the respondent Judge was dismissed from service in 1972; the criminal case against the police officers ended in acquittal; the Chief of Police died; and all respondent policemen had ceased to be connected with the Antipolo police force. Furthermore, the three underlying civil cases in the lower court had been either dismissed, archived, or reassigned.

ISSUE

Whether the petition for certiorari and prohibition assailing the lower court’s injunctive orders has been rendered moot and academic by supervening events.

RULING

Yes, the case is dismissed for being moot and academic. The Court’s ruling is anchored on the principle that judicial power is limited to the determination of actual controversies. A case becomes moot when there is no longer any justiciable controversy or when the issues presented have ceased to exist due to subsequent events, rendering any judicial declaration without practical legal effect.
The legal logic applied is straightforward: the core objective of the mayor’s petition was to nullify the restraining and injunctive orders issued by Judge Aquino, which were preventing the mayor from exercising disciplinary authority and maintaining peace and order through the appointed Constabulary officer. The Supreme Court’s own 1970 restraining order had already achieved a freeze on those contested lower court orders. More critically, the supervening events—specifically the death of the Chief of Police, the severance of all respondent policemen from the police department, the termination of the related criminal case, and the final disposition (dismissal or archiving) of the three underlying civil cases—have completely extinguished the live controversy. The administrative cases against the respondents are ipso facto terminated by their separation from service, and the injunctive orders being challenged have therefore become functus officio (having performed their office and thus devoid of force). With no actual substantial relief that the Court can grant, as the factual milieu that gave rise to the dispute has fundamentally and irrevocably changed, any adjudication on the merits would be an academic exercise without practical value. Consequently, the petition is dismissed.