G.R. No. 236271. April 03, 2019.
RO-ANN VETERINARY MANUFACTURING INC., RONILO DELA CRUZ AND RAFAELITO LAGAT, JR., PETITIONERS, VS. FERNANDO A. BINGBING, AND GILBERT C. VILLASEÑOR, RESPONDENTS.

FACTS

Respondents Fernando Bingbing and Gilbert Villaseñor were employed as technical sales representatives by petitioner Ro-Ann Veterinary Manufacturing, Inc. In March 2014, their clients received an advisory from the company stating the respondents were no longer connected with it. Their team leader, petitioner Rafaelito Lagat, Jr., confirmed he sent the advisories upon the company’s instruction. Petitioners contended respondents were involved in unexplained withdrawals of items and failed to remit collections, and had stopped reporting for work after a confrontation. Respondents argued the advisory constituted an express termination of their employment, which was illegal.
The Labor Arbiter (LA) ruled in favor of the respondents, declaring them illegally dismissed and awarding monetary claims. The National Labor Relations Commission (NLRC) affirmed the LA’s decision with modification. While petitioners’ appeal was pending before the Court of Appeals (CA) via a Rule 65 petition, the LA issued a Writ of Execution. The judgment award, including additional recomputed separation pay and backwages, was fully satisfied through garnishment of the company’s bank account and its cash bond. Respondents then filed an ex-parte manifestation stating the case had become moot due to this full satisfaction.

ISSUE

Whether the CA correctly dismissed the petition for certiorari for being moot and academic due to the full satisfaction of the judgment award.

RULING

Yes. The Supreme Court affirmed the CA’s dismissal. The core legal principle is that the full satisfaction of a judgment award renders a pending appeal moot and academic. A case becomes moot when there is no more actual controversy between the parties or no useful purpose can be served by a judicial pronouncement. Here, the petitioners voluntarily complied with the writ of execution by allowing the garnishment of their bank deposit and the application of their cash bond, leading to the complete satisfaction of the monetary judgment. This voluntary satisfaction of the judgment extinguished the petitioners’ cause of action. Consequently, any ruling from the CA on the merits of the petition for certiorari would be an exercise in futility, as it could no longer provide any practical relief to the petitioners. The Court emphasized that the doctrine of mootness is a matter of sound judicial policy, preventing the rendering of advisory opinions on abstract propositions. Therefore, the CA correctly dismissed the petition.