G.R. No. L-34574-79 June 30, 1980
EMILIANO O. OZAETA and REMIGIO CASTILLO, petitioners, vs. OIL INDUSTRY COMMISSION, ESSO PHILIPPINES, INC., MOBIL OIL PHILIPPINES, INC., CALTEX PHILIPPINES, INC., GETTY OIL (PHILIPPINES), INC., SHELL PHILIPPINES, INC., FILOIL REFINERY CORPORATION and FILOIL MARKETING CORPORATION, respondents.

FACTS

In November 1971, several oil companies filed applications with the Oil Industry Commission (OIC) for increases in the maximum selling prices of petroleum products. Concurrently, they filed motions for provisional relief, seeking temporary price hikes pending final resolution of their main applications. Petitioners Emiliano O. Ozaeta and Remigio Castillo opposed these motions, primarily arguing that the OIC lacked the statutory authority to grant such provisional increases. The OIC, in an Order dated December 20, 1971, denied the opposition and asserted its jurisdiction, citing its general powers under its charter. Petitioners moved for reconsideration, which was denied in an Order dated January 7, 1972. Consequently, petitioners filed this petition for prohibition before the Supreme Court on January 14, 1972, seeking to annul the OIC’s orders and to restrain it from hearing the motions for provisional relief. The Court issued a temporary restraining order on January 21, 1972, enjoining the OIC from conducting hearings on the provisional relief motions but allowing it to proceed with the main applications.

ISSUE

Whether the petition for prohibition, which sought to prevent the OIC from hearing and deciding motions for provisional price increases, has been rendered moot and academic.

RULING

Yes, the petition is moot and academic. The Supreme Court dismissed the petition on the ground that the actual controversy sought to be prohibited had ceased to exist. The legal logic is anchored on the judicial policy of deciding only actual, live controversies, not hypothetical or academic questions. The Court noted that the OIC had already decided the main applications for price increases on the merits by September 8, 1972, long before the Court’s resolution. Since the motions for provisional relief were merely interlocutory and ancillary to the main applications, the action sought to be prohibited—the hearing and trial of those motions—was no longer forthcoming. The primary objective of the petition was to stop a specific proceeding; with the main case concluded, that objective became impossible to grant. The Court found no compelling reason to rule on the substantive issue of the OIC’s authority to grant provisional increases, as such a ruling would be advisory. The temporary restraining order was consequently lifted. The dismissal for mootness reinforces the principle that the Court’s duty is to settle real disputes essential to the rights of the parties, not to render opinions on abstract propositions.