G.R. No. 191963 ; December 1, 2010
RITA NATAL, ET AL., Petitioners, vs. HON. MANUELITO O. CABALLES, Presiding Judge, Regional Trial Court – Branch 38, Boac, Marinduque, Public Respondent, MARCOPPER MINING CORP., Private Respondent.

FACTS

Petitioners filed a complaint for quasi-delict and tort against Marcopper Mining Corporation for damages arising from the flooding and siltation of the Mogpog river allegedly due to a dam breach. During the proceedings, petitioners filed a Motion for Production and Inspection of Objects/Property under Rule 27, seeking to compel Marcopper to produce documents and allow inspection of its dams and related structures. The respondent Judge required Marcopper to comment, set deadlines for filing, and deemed the motion submitted for resolution after the petitioners filed their reply on December 4, 2008.
Despite two motions for early resolution filed by petitioners in 2009, the respondent Judge did not act on the motion. Consequently, petitioners filed the present petition for mandamus on May 6, 2010, arguing that the judge failed to resolve the motion within the three-month period mandated by the Constitution. In response, both the respondent Judge and Marcopper pointed out that the motion had already been resolved by an Order dated March 11, 2010, which petitioners received on May 11, 2010, after filing the petition.

ISSUE

Whether the petition for mandamus to compel the respondent Judge to resolve the Motion for Production and Inspection has been rendered moot and academic.

RULING

Yes, the petition is dismissed on the ground of mootness. The Supreme Court held that an action becomes moot when it no longer presents a justiciable controversy because the issues have become academic or the matter in dispute has already been resolved, rendering judicial intervention unnecessary. Here, the respondent Judge issued the March 11, 2010 Order granting, in part, the petitioners’ motion for production and inspection. Since the very act sought to be compelled—the resolution of the motion—had already been performed, the petition lost its purpose. Courts will not adjudicate moot cases where a decision cannot affect the rights of the parties.
Nevertheless, the Court took note of the undue delay of almost fourteen months in resolving a simple motion, which contravenes the constitutional mandate for the speedy disposition of cases. However, the administrative aspect of this delay was not addressed in this proceeding, as an administrative case (OCA IPI No. 10-3376-RTJ) had already been filed against the judge with the Office of the Court Administrator. Thus, the petition was dismissed for being moot.