GR 132986; (May, 2004) (Digest)
G.R. No. 132986 ; May 19, 2004
JUAN PONCE ENRILE, petitioner, vs. SENATE ELECTORAL TRIBUNAL and AQUILINO PIMENTEL, JR., respondents.
FACTS
Senator Aquilino Pimentel, Jr. filed an election protest before the Senate Electoral Tribunal (SET) against Senator Juan Ponce Enrile and other winners of the May 1995 senatorial elections. After the revision of ballots in designated pilot precincts, the SET, without yet resolving the main protest, held a press conference and issued a press release titled “Partial Results in Pimentel’s Protest.” This release included a tabulation showing Enrile’s ranking had dropped. Enrile filed a motion to annul these partial results, alleging they were manifestly erroneous, and requested a new appreciation of ballots with all parties present.
The SET, in its assailed Resolution, acknowledged an oversight in the tally for Paoay, Ilocos Norte, and corrected it by restoring 30,000 votes to Enrile. However, it denied his motion, ruling there was no sufficient basis to discard the partial tabulation and that allowing party representation during the Tribunal’s appreciation of ballots would encroach on its judicial functions. Enrile’s motion for reconsideration was subsequently denied.
ISSUE
Whether the Senate Electoral Tribunal committed grave abuse of discretion in denying Enrile’s Motion to Set Aside Partial Results and to Conduct Another Appreciation of Ballots in the Presence of All Parties.
RULING
The Supreme Court dismissed the petition for being moot and academic. The legal logic is grounded in the principle that courts will not adjudicate cases where no actual justiciable controversy exists. The Court noted that the tenure of the contested senatorial position had already expired on June 30, 1998. Consequently, there was no longer any actual controversy between the parties, and a ruling on the merits would serve no practical purpose or provide substantial relief to the petitioner. The Court cited established jurisprudence, such as Garcia vs. COMELEC and Gancho-on vs. Secretary of Labor and Employment, which hold that courts decline jurisdiction over moot cases where the issues have become academic. Therefore, without reaching the substantive allegations of grave abuse of discretion, the petition was dismissed on procedural grounds due to its mootness.