GR 33650; (April, 1977) (Digest)
G.R. No. L-33650. April 22, 1977.
JOSE L.C. DIZON, petitioner, vs. HONORABLE COURT OF APPEALS, COURT OF AGRARIAN RELATIONS OF ANGELES CITY, PROVINCIAL SHERIFF OF PAMPANGA, JOSE LANSANGAN, GONZALO CUNANAN, GODOFREDO PAGUIO, LUCIO GARCIA and HORACIO BUNDOC, respondents.
FACTS
In 1966, the Court of Agrarian Relations (CAR) in Angeles City upheld the rights of tenants Gonzalo Cunanan, et al., to a rental reduction and a reliquidation of palay harvests from the land of petitioner Jose L.C. Dizon. The Court of Appeals affirmed this but remanded the case for the CAR to determine the specific allowable and excess rentals. After a hearing, the CAR rendered a supplemental decision on February 25, 1970, fixing the rentals and ordering Dizon to deliver 660 cavans and 22 kilos of palay (or its monetary value) to the five lessees. The CAR then issued an order on April 3, 1970, directing the execution of this supplemental judgment pending appeal. Dizon challenged this execution order before the Court of Appeals, which upheld the order in a decision dated March 25, 1971. Dizon appealed that decision to the Supreme Court on June 17, 1971.
ISSUE
Whether Dizon’s appeal to the Supreme Court, which assailed the Court of Appeals’ decision upholding the execution pending appeal of the CAR’s supplemental decision, had been rendered moot and academic.
RULING
Yes, the appeal was rendered moot. The Supreme Court dismissed the case. The legal logic is that the supervening event—the final decision of the Court of Appeals in the main case (CA-G.R. No. 44941-R) on November 25, 1975, which affirmed the very supplemental decision whose execution was being contested—had deprived Dizon’s present appeal of any practical legal effect. An appeal becomes moot when a court’s decision can no longer provide any effective relief because the substantive issue has been conclusively resolved by a subsequent, final judgment. Here, the supplemental decision, whose execution Dizon questioned, was ultimately affirmed on the merits. Therefore, the propriety of its execution pending appeal became an academic question. The Court further found Dizon’s ancillary argument questioning the CAR’s jurisdiction to render the supplemental decision as frivolous, noting that the CAR’s order for an alias writ of execution had already been upheld in a separate proceeding (G.R. No. L-44554), which was dismissed for lack of merit. Consequently, with the core judgment finally affirmed, the petition had “no more leg to stand on” and was dismissed.