GR 125560; (December, 2003) (Digest)
G.R. No. 125560; December 4, 2003
ELIZA FRANCISCO BAGGENSTOS, petitioner, vs. COURT OF APPEALS, REGIONAL TRIAL COURT OF ANTIPOLO, RIZAL, REGISTER OF DEEDS OF RIZAL, JOSEFINO DE GUZMAN and PACIFICO MAGNO, JR., respondents.
FACTS
Petitioner Eliza Francisco Baggenstos was declared in default in a collection case filed by respondent Josefino de Guzman for unpaid renovation costs. A writ of execution was issued, and a parcel of land registered in Baggenstos’s name was levied and sold at public auction to respondent Pacifico Magno, Jr. After the redemption period lapsed, Magno obtained an Officer’s Deed of Sale. Baggenstos refused to surrender the owner’s duplicate certificate of title, prompting Magno to file a petition to compel its surrender and for a writ of possession. Baggenstos opposed, claiming the default judgment was void due to improper service of summons. The trial court ruled against her, ordered the surrender of the title, and issued a writ of possession. Baggenstos subsequently filed a Petition for Annulment of Judgments with the Court of Appeals, which was denied for being insufficient in form and substance.
ISSUE
Whether the petition for review before the Supreme Court has been rendered moot and academic.
RULING
Yes, the petition is moot. The Supreme Court found that supervening events had rendered the case academic. The Register of Deeds had already cancelled Baggenstos’s Transfer Certificate of Title No. 171720 and issued a new title in the name of Pacifico Magno, Jr., on January 6, 1966. This act occurred long before Baggenstos filed her petition with the Court of Appeals in May 1996 and the instant petition with the Supreme Court in August 1996. A case becomes moot when there is no more actual controversy between the parties or no useful purpose can be served by a judicial pronouncement. Here, the core objective of Baggenstos’s action—to recover the title to the property—was already impossible to grant as the title had been lawfully transferred to a third party. The Court admonished Baggenstos’s counsel for filing frivolous petitions that clog court dockets, noting that while lawyers must defend their clients zealously, they are also officers of the court obligated to assist in the efficient administration of justice and should not misuse procedural rules to impede the execution of a final judgment. The petition was dismissed.