G.R. No. L-27785 August 11, 1976
HON. ZACARIAS A. TICZON (in his capacity as City Mayor of San Pablo City), petitioner-appellee, vs. HON. SERAFIN C. FULE (in his capacity as City Treasurer of San Pablo City), respondent-appellant.

FACTS

The case originated from a dispute between San Pablo City Mayor Zacarias A. Ticzon and City Treasurer Serafin C. Fule. The Mayor issued Office Order No. 64, directing the Treasurer to temporarily assign Isagani O. Ticzon as slaughterhouse guard and collector, replacing the incumbent Manuel Mendoza. City Treasurer Fule refused to comply, instead designating Oscar Baldovino for the position. Mayor Ticzon then filed a petition with the Court of First Instance of Laguna, which ruled in his favor and ordered Fule to obey the Office Order. Fule appealed this decision to the Supreme Court, raising the legal issue of the respective administrative powers of the City Mayor and the City Treasurer under the city charter.
By the time the Supreme Court was set to resolve the appeal, significant changes in circumstances had occurred. As manifested by the City Fiscal, Mayor Ticzon’s term had expired years prior, and City Treasurer Fule had retired from service in 1974. Furthermore, the specific position in dispute was no longer occupied by the original parties; the incumbent Manuel Mendoza had resigned, and the post was then held by Eufrocino Limdico. Oscar Baldovino, the treasurer’s appointee, had also retired.

ISSUE

Whether the appeal filed by City Treasurer Fule should be dismissed due to supervening events that rendered the case moot and academic.

RULING

Yes, the appeal is dismissed for being moot and academic. The Supreme Court applied the well-established principle that courts will not determine a case where no actual controversy exists between the parties or where the issues have ceased to be justiciable. The core legal question concerning the clash of administrative powers between the Mayor and the Treasurer was predicated on their official capacities. Both protagonists had long vacated their offices—Mayor Ticzon’s term expired, and Treasurer Fule retired. Consequently, the relief sought (compelling Fule to obey Ticzon’s order) could no longer be granted, as the official relationship and the specific factual context that gave rise to the dispute had been extinguished.
The Court also noted procedural grounds supporting dismissal. Respondent-appellant Fule failed to comply with the Court’s resolution to submit required copies of the lower court’s decision. More decisively, Fule himself filed a manifestation stating he was no longer desirous of prosecuting the appeal as it had “apparently become moot” and prayed for its dismissal. When an appellant voluntarily abandons the appeal and acknowledges the mootness of the case, the Supreme Court will dismiss it. The dismissal was rendered without costs, as no practical legal effect could flow from a resolution of the academic issue. The ruling underscores that judicial power is limited to actual cases and controversies, and courts do not adjudicate moot questions.