G.R. No. L-22643 August 30, 1973
Eugenio P. Miculob, petitioner, vs. Court of First Instance of Rizal, Quezon City Branch IX and J. M. Tuason & Co., Inc., represented by Gregorio Araneta, Inc., respondents.

FACTS

Petitioner Eugenio P. Miculob sought to nullify orders of the Court of First Instance of Quezon City denying his motion to suspend ejectment proceedings in Civil Case No. Q-4246, a suit filed by J.M. Tuason & Co., Inc. for recovery of possession of a 300-square-meter lot within the Tatalon Estate. Miculob, claiming to have purchased the lot in good faith and built his house thereon, moved for suspension under Republic Act No. 3516 . This law provided for a two-year suspension of ejectment proceedings against occupants of landed estates authorized for expropriation, such as the Tatalon Estate, upon the defendant’s motion.
The lower court denied the motion, ruling that suspension under RA 3516 required either a pending expropriation action or government possession with contemporaneous compensation, citing prior jurisprudence. The private respondent, J.M. Tuason & Co., Inc., asserted its registered title and argued that the lot was not part of a landed estate subject to expropriation. It further contended that RA 3516 was unconstitutional, relying on several Supreme Court precedents.

ISSUE

Whether the petition to nullify the lower court’s orders and to secure a suspension of the ejectment proceedings under RA 3516 has been rendered moot and academic.

RULING

Yes, the petition is dismissed as moot and academic. The legal landscape was fundamentally altered by the issuance of Presidential Letter of Instructions No. 34 on October 27, 1972. This directive ordered the People’s Homesite and Housing Corporation to acquire the Tatalon Estate, either by negotiation or expropriation under Republic Act No. 2616 , and to subdivide it for distribution to bona fide occupants. Consequently, an expropriation complaint was filed by the government against J.M. Tuason & Co., Inc. on January 23, 1973, and a writ of possession was subsequently issued.
All parties conceded to the mootness of the case. The private respondent manifested that the expropriation action had commenced. The petitioner agreed the case was moot and confirmed he had filed an application with the proper authorities to acquire the lot he occupied. The Solicitor General also stated the constitutional issue regarding RA 3516 was rendered academic by LOI 34, though he noted the petitioner’s separate right to seek acquisition of the lot in the ensuing administrative or judicial proceedings. Since the supervening event of LOI 34 and the initiation of expropriation achieved the core objective sought by the petitioner—state intervention to acquire the estate—the original controversy over the suspension of ejectment under RA 3516 lost its practical legal significance. The Court, therefore, dismissed the petition.