G.R. No. L-34697 February 28, 1973
REPARATIONS COMMISSION, petitioner, vs. THE HONORABLE JORGE COQUIA, Presiding Judge, Branch XI, Court of First Instance of Manila, and ARCADIA MANUFACTURING INC., respondents.

FACTS

The Reparations Commission filed a petition for certiorari with preliminary injunction seeking to annul two orders from respondent Judge Jorge Coquia. These orders, dated October 30 and December 16, 1971, directed the Commission to comply with a writ of preliminary injunction issued in Civil Case No. 63518. The injunction mandated the Commission to apply a specific foreign exchange rate of two Philippine pesos to one U.S. dollar to the embroidery plant project of respondent Arcadia Manufacturing Inc., restraining the Commission from applying any other rate.
In their Answer and subsequent pleadings, respondents asserted that the petition had become moot and academic. They informed the Supreme Court that the Commission had already given due course to Arcadia’s additional allocation and issued a corresponding procurement order on March 6, 1972. More critically, respondents reported that the Court of Appeals had dismissed the Commission’s appeal from the main decision in Civil Case No. 63518 in a resolution dated April 12, 1972, which had subsequently become final.

ISSUE

Whether the petition for certiorari had been rendered moot and academic by supervening events.

RULING

Yes, the petition is dismissed for being moot and academic. The Supreme Court applied the well-settled doctrine that courts will not determine questions that no longer present an actual, substantial controversy. A case becomes moot when its resolution would have no practical legal effect because the issues have been overtaken by events or the parties no longer have a legally cognizable interest in the outcome.
Here, two supervening events extinguished the justiciable controversy. First, the petitioner Commission had already voluntarily performed the very act sought to be enjoined by implementing Arcadia’s allocation, thereby granting the substantive relief involved. Second, and decisively, the Court of Appeals’ dismissal of the appeal from the main decision in the underlying civil case had become final and executory. Consequently, the trial court’s decision, which included the injunction order incidental to it, became the law of the case. The ancillary matter of enforcing the preliminary injunction could not survive the finality of the main judgment from which it sprang. Since no useful purpose would be served by further proceedings, the Court dismissed the petition.