GR 139460; (March, 2006) (Digest)
G.R. No. 139460; March 31, 2006
KOREA EXCHANGE BANK, Petitioner, vs. HON. ROGELIO C. GONZALES, et al., Respondents.
FACTS
Private respondents Phi-Han Development, Inc. and its individual stockholders (Magno, et al.) filed a Complaint for collection of sum of money with damages against petitioner Korea Exchange Bank (the Bank) and Jae Il Aum before the RTC of Guagua, Pampanga. They alleged that a US$500,000 loan secured by a mortgage on their properties was deposited with the Bank under accounts where Aum and respondent Mendoza were designated signatories. They claimed that Aum, with the Bank’s indispensable cooperation, subsequently withdrew US$160,000 using a withdrawal application with a forged signature of Mendoza, draining the deposits to their prejudice.
The Bank filed a Motion to Dismiss on grounds of lack of jurisdiction, improper venue, lack of cause of action, and lack of legal capacity to sue (as some plaintiffs were married women). The RTC denied the motion. The Court of Appeals dismissed the Bank’s subsequent Rule 65 petition, upholding the RTC’s order. The Bank elevated the case via a Petition for Review under Rule 45.
ISSUE
Whether the Supreme Court should resolve the substantive issues raised in the Petition for Review.
RULING
The Supreme Court denied the petition for being moot and academic. The legal logic is grounded in the principle that courts will not determine moot questions. A justiciable controversy must exist at all stages of judicial review. Here, the core dispute—the collection case before the RTC—had already been finally adjudicated in a separate proceeding (G.R. Nos. 142286-87, decided April 15, 2005), wherein the Supreme Court affirmed the dismissal of the complaint against the Bank on the merits. Consequently, the present petition, which assails the interlocutory order denying the motion to dismiss in that same now-terminated case, no longer presents an active controversy where any judicial determination could grant practical relief or substantial redress to the petitioner. When issues become moot, judicial intervention ceases to be necessary as there is no longer any real, substantial relief to which a party may be entitled. The Court therefore abstained from expressing an opinion on the procedural and substantive arguments initially raised, as any ruling would be purely academic and of no legal consequence.