G.R. No. 240873, September 03, 2019
SOLICITOR GENERAL JOSE C. CALIDA, MILAGROS O. CALIDA, JOSEF CALIDA, MICHELLE CALIDA, AND MARK JOREL CALIDA, PETITIONERS, VS. SENATOR ANTONIO “SONNY” TRILLANES IV, THE COMMITTEE ON ACCOUNTABILITY OF PUBLIC OFFICERS AND INVESTIGATIONS (BLUE RIBBON COMMITTEE), AND THE COMMITTEE ON CIVIL SERVICE, GOVERNMENT REORGANIZATION, AND PROFESSIONAL REGULATION, RESPONDENTS.

FACTS

Petitioners, Solicitor General Jose C. Calida and his family, filed a Petition for Certiorari and Prohibition seeking to permanently prohibit then-Senator Antonio Trillanes IV from conducting a legislative inquiry into their alleged conflict of interest regarding government contracts awarded to their security services company, Vigilant Investigative and Security Agency, Inc., based on Proposed Senate Resolution No. 760. They argued the resolution lacked intended legislation, the invitations were issued without Senate body approval, and the investigation aimed to target and humiliate them. They also prayed for a temporary restraining order. Respondent Trillanes countered that the resolution underwent first reading and was formally referred to the Committee on Civil Service (which he chaired) and the Blue Ribbon Committee, and that the invitations were sent in his official capacity. He further stated that after a change in referral, the Blue Ribbon Committee became the primary committee, rendering the initial hearing by his committee functus officio and the scheduled hearing moot. He also emphasized the invitations were not subpoenas, so petitioners were under no legal compulsion to attend. Petitioners later filed a Supplemental Petition to implead the two Senate committees.

ISSUE

Whether or not respondents, then Senator Antonio “Sonny” Trillanes IV, the Committee on Accountability of Public Officers and Investigations, and the Committee on Civil Service, Government Reorganization, and Professional Regulation, should be enjoined from conducting hearings in aid of legislation over Proposed Senate Resolution No. 760.

RULING

The Petition has no merit. The case was dismissed for being moot and academic. The Court held that a case becomes moot when it loses its justiciability as there is no longer a conflict of legal rights requiring judicial resolution. The Court took judicial notice that Proposed Senate Resolution No. 760 was filed during the 17th Congress, which closed on June 4, 2019. With the closing of that Congress, the investigation into the proposed resolution was terminated, rendering the petition moot. The Court found that none of the exceptions to the mootness doctrine—such as a grave constitutional violation, paramount public interest, need to formulate controlling principles, or the issue being capable of repetition yet evading review—were applicable in this case. Thus, the Court could no longer rule on the propriety of enjoining the legislative inquiry.