G.R. No. 222070 . APRIL 16, 2018.
EMMANUEL M. LU, ROMMEL M. LU, CARMELA M. LU, KAREN GRACE P. LU and JAMES MICHAEL LU, Petitioners, vs. MARISSA LU CHIONG and CRISTINA LU NG, Respondents.

FACTS

Respondents Marissa Lu Chiong and Cristina Lu Ng filed two complaints with the Regional Trial Court (RTC) of Calamba City, Branch 34, seeking to nullify the stockholders’ meetings and elections of directors and officers of Remcor Industrial and Manufacturing Corporation and Soutech Development Corporation. During the pendency of these cases, respondents filed Motions for Inhibition against Presiding Judge Maria Florencia Formes-Baculo, alleging bias and partiality. On February 18, 2015, Judge Formes-Baculo issued twin Orders granting the motions and voluntarily inhibiting herself from the cases, stating it would dispel notions of prejudgment.
Respondents then filed a Consolidated Petition for Certiorari and Prohibition with the Court of Appeals (CA) to challenge the inhibition orders. The CA granted the petition on September 11, 2015, reversing the RTC’s orders and directing the return of the cases to Branch 34, ruling that voluntary inhibition must be based on just or valid reasons, not mere imputations. Petitioners’ motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in not dismissing the certiorari petition (CA-G.R. SP No. 139683) on the ground of mootness.

RULING

Yes, the Supreme Court granted the petition and reversed the CA. The core legal principle applied is that courts will not adjudicate moot and academic cases, which cease to present a justiciable controversy such that a ruling would have no practical legal effect. The pivotal fact rendering the CA proceeding moot was the RTC, Branch 35 of Calamba City’s issuance of a Consolidated Decision on July 13, 2015, which had already resolved and dismissed the main complaints on their merits. This decision was promulgated prior to the CA’s September 11, 2015 Decision.
Since the main actions had been finally disposed of by a court of competent jurisdiction (Branch 35), the ancillary issue concerning Judge Formes-Baculo’s inhibition from the earlier proceedings in Branch 34 was thereby overtaken. Any declaration on the propriety of her inhibition would be of no practical value, as the substantive case had concluded. The CA should have dismissed the certiorari petition on the ground of mootness. The Supreme Court found this ground sufficient to resolve the petition, making it unnecessary to rule on the other procedural and substantive arguments raised by the petitioners.