GR 33669; (March, 1977) (Digest)
G.R. No. L-33669. March 31, 1977.
HEIRS OF D. TUAZON, INC., HON. WENCESLAO G. CORNEJO, Judge of the City Court of Manila, Branch V, and CITY SHERIFF of Manila, petitioners, vs. HON. SIMEON GOPENGCO, Judge of the Court of First Instance of Manila, Branch XXV, and ENRIQUE C. SALINAS, doing business under the name and style of KENTUCKY FRIED CHICKEN RESTAURANT and/or HERMITAGE, respondents.
FACTS
The Heirs of D. Tuazon, Inc. secured a final and executory judgment from the Manila City Court on March 9, 1970, in an ejectment case (Civil Case No. 186982). The judgment ordered respondent Enrique C. Salinas to vacate the leased premises on Ramon Magsaysay Boulevard and to pay back rentals. To forestall the execution of this final judgment, Salinas filed a petition for certiorari and prohibition with the Court of First Instance (CFI) of Manila (Civil Case No. 80223), seeking to enjoin its enforcement.
The CFI initially issued a preliminary injunction but later dissolved it upon the petitioner’s motion. Subsequently, upon Salinas’s motion for reconsideration, the CFI, in its Order dated March 2, 1971, revived the injunction against the execution of the city court’s final judgment. This CFI order, which effectively restrained the enforcement of a final and executory lower court decision, prompted the petitioners to elevate the matter to the Supreme Court via the instant petition for certiorari and prohibition.
ISSUE
Whether the Supreme Court could rule on the propriety of the CFI’s order enjoining the execution of a final city court judgment, given supervening events.
RULING
The Supreme Court dismissed the petition as moot and academic. The legal logic is grounded in the judicial principle that courts will not determine cases where no actual substantial controversy exists or where the issues have been rendered academic by subsequent events. During the pendency of the Supreme Court petition, the parties in the underlying CFI case (Civil Case No. 80223) entered into a compromise agreement. This compromise was approved by the CFI in its decision dated October 18, 1971.
The petitioner, Heirs of D. Tuazon, Inc., formally moved to dismiss the Supreme Court petition on this ground of compromise, and respondent Salinas manifested no objection to the dismissal. Consequently, the very subject of the petition—the CFI’s order enjoining execution—was superseded and settled by the compromise judgment. There was no longer any live dispute for the Supreme Court to adjudicate. The Court therefore refrained from making a determination on the merits, as any ruling would have no practical legal effect. The case was terminated without costs.