G.R. No. 192302, June 4, 2014.
Republic of the Philippines, represented by the Anti-Money Laundering Council, Petitioner, vs. Rafael A. Manalo, Grace M. Oliva, and Freida Z. Rivera-Yap, Respondents.

FACTS

The petitioner, the Republic of the Philippines represented by the Anti-Money Laundering Council (AMLC), filed two complaints for civil forfeiture before the Regional Trial Court (RTC) of Manila, Branch 24. The cases, docketed as Civil Case Nos. 03-107308 and 03-107325, sought the forfeiture of bank accounts and government securities allegedly related to the unlawful activity of fraudurulently accepting public investments in violation of the Securities Regulation Code and the Anti-Money Laundering Act. The respondents, Rafael A. Manalo, Grace M. Oliva, and Freida Z. Rivera-Yap, filed separate Motions for Leave to Intervene and Admit Attached Answer-in-Intervention in these civil forfeiture cases. They claimed a legal interest in the subject bank accounts, asserting that they had been appointed as assignees of the properties of Spouses Saturnino and Rosario Baladjay (who were defendants in the forfeiture cases) in separate involuntary insolvency proceedings (Spec. Proc. Case No. 03-026) before the RTC of Makati City. The Manila RTC denied the motions for intervention, citing Section 35 of the Rule of Procedure in Cases of Civil Forfeiture, which allows a person claiming an interest in forfeited property to file a verified petition for its segregation or exclusion within fifteen days from the finality of the order of forfeiture. The RTC reasoned that this provision amply protected the respondents. The respondents moved for reconsideration, which was denied. They then elevated the case to the Court of Appeals (CA) via certiorari. The CA granted the petition, ruling that the Manila RTC gravely abused its discretion in denying the motions for intervention. The CA found that the respondents had established their rights as assignees and that Section 35 of the Civil Forfeiture Rules did not prohibit intervention before an order of forfeiture is issued. The Republic’s motion for reconsideration was denied by the CA, prompting this petition for review on certiorari. During the pendency of this petition, the Manila RTC rendered Decisions (dated September 23, 2010; February 11, 2011; and an Amended Decision dated May 9, 2011) in the underlying civil forfeiture cases, ordering the forfeiture of the subject assets in favor of the government.

ISSUE

Whether or not the Court of Appeals erred in holding that the Manila RTC committed grave abuse of discretion in issuing the Joint Order dated August 8, 2007 and the Order dated January 10, 2008 which denied respondents’ separate motions for intervention in the civil forfeiture cases.

RULING

The Supreme Court dismissed the petition for being moot and academic. A case becomes moot and academic when supervening events cease to present a justiciable controversy, rendering a declaration on the issue of no practical value or use. The supervening events in this case were the Manila RTC’s rendition of Decisions and an Amended Decision in the civil forfeiture cases, which ordered the forfeiture of the assets in favor of the government. Since the proceedings in the main civil forfeiture cases, from which the issue of intervention was merely an incident, had already been concluded, no substantial relief could be granted by resolving the petition. The essential issue of whether the respondents should have been allowed to intervene was therefore rendered moot.