G.R. No. 167989-93, March 6, 2007
TEODORO M. JUMAMIL, et al., Petitioners, vs. COMMISSION ON ELECTIONS, et al., Respondents.

FACTS

Petitioners and private respondents were opposing candidates in the May 2004 local elections in Victoria, Northern Samar, for positions including mayor, vice-mayor, and sangguniang bayan members. Private respondents were proclaimed winners. Petitioners subsequently filed consolidated election protests before the Regional Trial Court (RTC) of Allen, Northern Samar, Branch 23, contesting the results in several precincts. The RTC denied private respondents’ motion to dismiss and their prayer to conduct a hearing or pre-trial prior to the revision of ballots, ordering the revision to proceed.
Private respondents then filed a Petition for Certiorari with the COMELEC, assailing the RTC’s orders and seeking a writ of preliminary injunction to halt the revision. The COMELEC First Division granted the writ in an Order dated February 12, 2005, effectively enjoining the RTC from proceeding with the election protest cases. Petitioners elevated the matter to the Supreme Court via the present consolidated petitions, arguing the COMELEC committed grave abuse of discretion in issuing the injunction.

ISSUE

Whether the Supreme Court should grant the petitions for certiorari assailing the COMELEC’s Order that issued a writ of preliminary injunction against the RTC’s proceedings.

RULING

The Supreme Court dismissed the petitions for being moot and academic. The legal logic is grounded on the principle that courts will not determine questions that no longer present an actual controversy. During the pendency of the Supreme Court petitions, the COMELEC had already rendered final resolutions on the merits of the main Petitions for Certiorari filed by the private respondents. Specifically, the COMELEC dismissed all those petitions for lack of merit. Consequently, the ancillary writ of preliminary injunction issued by the COMELEC, which was the sole subject of the challenge before the Supreme Court, was thereby dissolved by the final dismissal of the main cases. There was no longer any live injunction order to nullify or any legal relief that could be granted to the petitioners. The Court emphasized that it does not adjudicate moot cases, as its power is limited to the determination of actual controversies affecting legally demandable rights. Since the COMELEC’s final resolutions had rendered the injunction issue academic, any ruling by the Supreme Court on the propriety of the now-dissolved injunction would be an exercise in futility and an inefficient use of judicial resources.