GR 30072; (August, 1978) (Digest)
G.R. No. L-30072 August 31, 1978
ALATCO TRANSPORTATION, INC., BICOL TRANSPORTATION CO., INC., and CONSOLIDATED AUTO LINES, INC., petitioners, vs. JOSE NAYVE and PUBLIC SERVICE COMMISSION, respondents.
FACTS
The petitioners, Alatco Transportation, Inc., Bicol Transportation Co., Inc., and Consolidated Auto Lines, Inc., filed this certiorari case to challenge an order issued by the Public Service Commission (PSC) on December 20, 1968. That order had provisionally approved the application of respondent Jose Nayve for a certificate of public convenience to operate a PUB auto-truck service with five units on the Guinobatan, Albay to Legaspi City line and vice-versa. This Court issued a writ of preliminary injunction on May 29, 1969, to restrain the enforcement of the PSC’s order, and later amended it on January 9, 1970, to direct the Commission to suspend consideration of Nayve’s application.
ISSUE
The primary issue presented was the validity of the PSC’s provisional order granting Nayve’s application. However, a supervening question arose on whether the case had been rendered moot and academic by subsequent events, thereby precluding the need for a substantive ruling on the original challenge.
RULING
The Supreme Court dismissed the case for being moot and academic. The legal logic for dismissal rests on the well-established judicial principle that courts will not determine abstract, hypothetical, or dead questions that no longer present a live, justiciable controversy. A case becomes moot when its resolution would have no practical legal effect because the issues have ceased to exist or the parties lack a legally cognizable interest in the outcome.
Here, the Court, in a resolution dated January 30, 1978, directed the parties to inform it whether supervening events had rendered the case moot. Both the petitioners’ counsel and the Solicitor General, representing the PSC (now the Board of Transportation), filed manifestations confirming this status. They stated that respondent Nayve had ceased to be a bus operator and that the business of petitioner Alatco Transportation Co., Inc., had been absorbed by Pantranco South Express, Inc. Consequently, the underlying dispute over the provisional franchise lost its practical significance, as the operational landscape and the parties’ interests had fundamentally changed. Since no active controversy remained for judicial resolution, the Court was compelled to dismiss the petition without reaching the merits of the assailed PSC order. No costs were awarded.