G.R. No. L-32401. August 10, 1976.
HUSING LAO, petitioner, vs. HON. FELINO D. ABALOS, Judge of the Court of First Instance of Sulu, Branch II, 16th Judicial District, and ESTEBAN T. BUMANGLAG, respondents.

FACTS

This case originated from an administrative complaint filed by Husing Lao against Municipal Judge Esteban T. Bumanglag of Pangutaran, Sulu, docketed as Administrative Case No. 69-MJ. During the hearing of this administrative case, an evidentiary issue arose. Petitioner Lao sought to present testimony from the chief of police regarding certain police blotters. Respondent Judge Bumanglag objected to this testimony on the grounds that the blotters were not produced in court by their official custodian and there was no showing that they were official records. Presiding Judge Felino D. Abalos sustained the objection, ruling that the chief of police could not testify on the blotters under those circumstances.
Aggrieved by this interlocutory ruling, petitioner Lao filed the instant certiorari and mandamus case before the Supreme Court. He sought the annulment of Judge Abalos’s order, arguing it constituted a grave abuse of discretion. The respondents filed their answer, and the case was submitted for decision by the Supreme Court on January 11, 1971.

ISSUE

The core legal issue presented was whether Judge Abalos committed grave abuse of discretion in sustaining the objection to the testimony of the chief of police regarding the police blotters, based on the grounds of non-production by the custodian and lack of proof of their official character.

RULING

The Supreme Court dismissed the case for being moot and academic. The Court’s resolution was based on supervening events that rendered a decision on the substantive legal issue unnecessary. The administrative case from which this petition arose, Administrative Case No. 69-MJ, had itself become moot. The Court noted that the resignation of respondent Judge Esteban T. Bumanglag had been accepted by the President of the Philippines on November 24, 1972, which occurred before the administrative investigation could be concluded. Consequently, in a prior resolution dated June 29, 1976, the Supreme Court had already dismissed the underlying administrative case for having become moot.
Furthermore, the petitioner’s own counsel, in a manifestation dated August 2, 1976, conceded that the issue in this certiorari proceeding had likewise become moot. Since the administrative proceeding against Judge Bumanglag was terminated by his resignation and the dismissal of the case, any ruling on the propriety of the evidentiary order issued during its investigation would have no practical legal effect. The Court, therefore, applied the well-settled doctrine that courts will not determine questions that no longer present a justiciable controversy. The petition was dismissed without costs.