GR 116526; (March, 2004) (Digest)
G.R. No. 116526; March 23, 2004
Carmen Soriano Vda. De Dabao, petitioner, vs. Court of Appeals, Paluwagan ng Bayan Savings and Loan Bank, Register of Deeds of Paranaque, M.M., respondents.
FACTS
Petitioner Carmen Soriano Vda. de Dabao filed an action for annulment of deeds of sale and recovery of property, claiming that the subject land, originally in her deceased husband’s name, was fraudulently transferred to spouses Charlie and Mary Grace Dabao via a forged deed of sale. The spouses then mortgaged the property to respondent Paluwagan ng Bayan Savings and Loan Bank. Upon the spouses’ loan default, the bank extrajudicially foreclosed the mortgage and purchased the property at auction. The Regional Trial Court granted Carmen’s application for a writ of preliminary injunction to prevent the bank from consolidating title, upon posting of a bond.
Respondent bank filed a petition for certiorari with the Court of Appeals, arguing the trial court committed grave abuse of discretion in issuing the injunction despite finding the bank to be an innocent mortgagee. The appellate court granted the petition, annulled the RTC’s orders, and lifted the preliminary injunction. Carmen’s motion for reconsideration was denied, prompting this petition.
ISSUE
Whether the Court of Appeals erred in nullifying the RTC’s orders granting the preliminary injunction.
RULING
The Supreme Court dismissed the petition for being moot and academic. The Court took judicial notice of a separate, final, and executory decision of the Court of Appeals in CA-G.R. CV No. 60399, which definitively adjudicated the main controversy. In that decision, the appellate court affirmed the validity of the mortgage and foreclosure, and declared respondent bank to be an innocent purchaser for value and the absolute owner of the disputed property.
The legal logic is grounded in the principle of mootness. An issue becomes moot when it ceases to present a justiciable controversy, rendering a ruling of no practical legal value. The raison d’être of the instant petition was to secure injunctive relief pending the determination of ownership in the main case. However, with the finality of the decision in CA-G.R. CV No. 60399, which conclusively resolved the issue of ownership in favor of the bank, the reliefs sought by petitioner—both in this certiorari petition and in the underlying civil case—were no longer legally feasible. Courts generally decline to exercise jurisdiction over moot cases where no actual substantial relief can be granted. Consequently, the petition was dismissed.