GR 157236; (November, 2006) (Digest)
G.R. Nos. 157236-45; November 16, 2006
Romeo D. Lonzanida, Petitioner, vs. The Hon. Sandiganbayan (Fourth Division), Respondent.
FACTS
Petitioner Romeo D. Lonzanida was convicted by the Sandiganbayan of ten counts of Falsification of Public Document in a Decision dated October 20, 2000. After his motion for reconsideration was denied, he moved that it be treated as a motion for new trial based on newly discovered evidence. The Sandiganbayan initially denied this but later granted a new trial “in the supreme interest of justice,” conducted hearings, and required memoranda. A promulgation of a new judgment was scheduled.
However, instead of promulgating a new decision, the Sandiganbayan issued a Resolution on January 21, 2003, declaring its original 2000 Decision “final and executory” and ordering petitioner’s arrest. Both petitioner and the Office of the Special Prosecutor filed motions for clarification, with the prosecution asserting that a new judgment should be rendered. The Sandiganbayan cancelled the promulgation and took the motions under advisement.
ISSUE
Whether the petition for certiorari and prohibition to annul the Sandiganbayan’s January 21, 2003 Resolution has been rendered moot and academic.
RULING
Yes, the petition is dismissed for being moot and academic. The core issue raised was the propriety of the January 21, 2003 Resolution, which declared the 2000 Decision final despite the prior grant of a new trial. This controversy was rendered academic by a supervening event: the Sandiganbayan itself promulgated a new Decision on July 25, 2003. This subsequent Decision again found petitioner guilty but expressly set aside the very January 21, 2003 Resolution that petitioner sought to annul.
The legal logic is grounded in the principle of mootness. Courts will not determine cases where no actual substantial controversy exists or where the issues have ceased to be justiciable. The object of the petition—to nullify the January 21, 2003 Resolution—was effectively achieved by the Sandiganbayan’s own subsequent action in vacating that Resolution. Therefore, granting the relief prayed for would be superfluous, as the assailed Resolution had already been superseded and rendered inoperative. The Supreme Court thus dismissed the petition, as the supervening Decision of July 25, 2003 mooted the case.