GR 184496; (December, 2013) (Digest)
G.R. No. 184496; December 2, 2013
Hadji Hashim Abdul, Petitioner, vs. Honorable Sandiganbayan (Fifth Division) and People of the Philippines, Respondents.
FACTS
Petitioner Hadji Hashim Abdul, then Municipal Mayor of Mulondo, Lanao del Sur, was charged with falsification of public documents under the Revised Penal Code in 2002. The Office of the Special Prosecutor moved for his mandatory suspension pendente lite under Section 13 of Republic Act No. 3019 (Anti-Graft Act). The Sandiganbayan granted the motion and ordered a 90-day suspension in 2003. Petitioner challenged this via a Petition for Certiorari, but the Supreme Court dismissed it, and the dismissal became final in 2004. However, the suspension order was not implemented as petitioner’s second mayoral term expired and he lost his re-election bid in May 2004.
Petitioner won again as mayor in the May 2007 election. In 2008, the prosecution moved to implement the 2003 suspension order. The Sandiganbayan, in a Resolution dated May 14, 2008, ordered his suspension anew. Petitioner filed a Motion for Reconsideration, arguing the issue had been rendered moot by his 2004 electoral defeat, but it was denied. He then filed the instant Petition for Certiorari, alleging grave abuse of discretion.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in ordering petitioner’s suspension pendente lite in 2008.
RULING
The Supreme Court dismissed the petition for being moot and academic. The core legal principle is that courts will not adjudicate cases where no justiciable controversy exists because a judgment would have no practical legal effect. While the petition initially presented a live issue regarding the propriety of the suspension order, a supervening event—petitioner’s acquittal by the Sandiganbayan in a Decision promulgated on November 24, 2009—rendered the case moot. The suspension pendente lite is an incident of the criminal prosecution; with petitioner’s acquittal, the legal basis for the suspension ceased to exist. Consequently, any ruling on the alleged grave abuse of discretion in issuing the 2008 suspension order would be an academic exercise with no practical value. The Court emphasized that it does not sit to decide moot questions or satisfy scholarly interest. Thus, the petition was dismissed.