G.R. No. L-27600 January 22, 1981
FAUSTINO RONCESVALLES, petitioner, vs. LUIS PATOLA AND HONORABLE JUDGE VALERIANO A. DEL VALLE, COURT OF AGRARIAN RELATIONS, Ninth Regional District, Branch II, respondents.

FACTS

Petitioner Faustino Roncesvalles filed this petition for certiorari, prohibition, and mandamus to challenge an interlocutory order issued by the Court of Agrarian Relations (CAR). The order, issued in an ejectment case filed by landowner Luis Patola, temporarily dispossessed Roncesvalles, the alleged tenant, without a full hearing on the merits of the case. The CAR justified the order based on Roncesvalles’s alleged persistent refusal to deliver the landowner’s share of the harvest, an act deemed a proper ground for such provisional remedy under the then-applicable tenancy law.
Subsequently, the Supreme Court required the parties to manifest whether the petition had become moot and academic, given the significant lapse of time without a decision on the merits. Private respondent Patola manifested that the underlying agrarian case had been settled amicably and dismissed in the lower court. In contrast, counsel for petitioner Roncesvalles failed to file any responsive pleading or manifestation despite being given an opportunity, leaving the respondent’s manifestation uncontested.

ISSUE

Whether the petition assailing the CAR’s interlocutory order for temporary dispossession has been rendered moot and academic.

RULING

Yes, the petition is dismissed for being moot and academic. The core legal issue regarding the propriety of an interlocutory dispossession order without a full hearing is no longer justiciable. The Court’s resolution is grounded on the supervening event that the parties have amicably settled the main ejectment case pending before the CAR, leading to its dismissal. A case becomes moot when there is no more actual controversy between the parties or the issues have ceased to exist.
The Court noted the failure of petitioner’s counsel to contest the respondent’s manifestation of settlement, which remained uncontroverted for months. Furthermore, the Court observed that even if the merits were reached, the legal landscape had significantly shifted with the enactment of Presidential Decree No. 27, which fundamentally altered tenancy relations. Under this decree, a bona fide tenant’s rights would be fully protected, thereby diminishing the contemporary significance of the specific procedural question raised under the prior tenancy law. Consequently, the Court found no compelling reason to resolve the academic question and terminated the case.