GR 202678; (September, 2018) (Digest)
G.R. No. 202678 , September 05, 2018
ERNESTINA A. PAGDANGANAN, ET AL., PETITIONERS, V. THE COURT OF APPEALS AND MA. SUSANA A.S. MADRIGAL, ET AL., RESPONDENTS.
FACTS
The petitioners, heirs of a minority stockholder and other parties in Solid Guaranty, Inc., were involved in a protracted intra-corporate dispute. The core litigation began with an interpleader suit filed in 2007 concerning conflicting claims over corporate shares. During its pendency, a series of special stockholders’ meetings were called, leading to the election of new directors. The petitioners challenged the Regional Trial Court’s (RTC) orders permitting these meetings via a Petition for Certiorari, Prohibition, and Mandamus filed with the Court of Appeals (CA) in July 2008, docketed as CA-G.R. SP No. 104291. The case underwent multiple supplemental pleadings, with the CA issuing various procedural resolutions. By 2012, after nearly four years without a final judgment on the main petition, the petitioners filed the instant Petition for Mandamus before the Supreme Court, alleging inordinate delay by the CA in resolving CA-G.R. SP No. 104291, thereby violating their constitutional right to the speedy disposition of cases.
ISSUE
Whether the Petition for Mandamus to compel the Court of Appeals to resolve CA-G.R. SP No. 104291 has been rendered moot and academic.
RULING
Yes, the petition is moot and academic. The Supreme Court held that a petition for mandamus becomes moot when the act sought to be compelled—in this case, the resolution of the case by the Court of Appeals—is subsequently performed. The records revealed that during the pendency of this Supreme Court petition, the CA had in fact promulgated a Resolution on March 10, 2014, which denied the petitioners’ motion for reconsideration of a prior CA Decision. This CA Resolution had attained finality and was entered in the Book of Entries of Judgments on April 23, 2014. Consequently, the primary objective of the mandamus petition, which was to secure a ruling from the appellate court, was already accomplished. The Court emphasized that it will not determine cases where no actual substantial controversy exists or where the issues have been overtaken by events. Since the CA had finally disposed of the subject case, any ruling by the Supreme Court on the alleged delay would be ineffectual and would provide no practical relief to the petitioners. The petition was therefore dismissed for being moot.