G.R. No. L-36008 November 28, 1980
MAURO G. AGDA, petitioner, vs. CRISPIN N. SAN JUAN and HONORABLE JUDGE BUENAVENTURA J. GUERRERO of the Court of First Instance of Rizal, Br. XXIV, respondents.

FACTS

Petitioner Mauro G. Agda and private respondent Crispin N. San Juan were candidates for municipal councilor of Rodriguez (formerly Montalban), Rizal, in the November 8, 1971 elections. The municipal board of canvassers initially withheld the proclamation for the eighth councilor slot per a COMELEC resolution. Subsequently, on December 14, 1971, Agda was proclaimed the winner for the eighth position by a margin of one vote, having received 2,849 votes against San Juan’s 2,848. Dissatisfied, San Juan filed an election protest on December 24, 1971, before the Court of First Instance of Rizal, challenging the results in ten precincts. Agda, in turn, filed a counter-protest questioning the results in fourteen precincts.
The respondent court appointed revision committees to conduct a physical count and examination of the ballots from the contested precincts. After the revision proceedings and trial, the court rendered a decision on December 14, 1972, in favor of San Juan, declaring him the duly elected eighth councilor by a plurality of one vote. Aggrieved, Agda elevated the matter to the Supreme Court via a petition for review on certiorari, contending that the trial court committed errors in the appreciation of the disputed ballots.

ISSUE

Whether the Supreme Court should proceed to review the merits of the election protest concerning the 1971 elections, given the supervening event of a new local election held in January 1980.

RULING

The Supreme Court dismissed the petition, declaring the case moot and academic. The legal logic is anchored on the principle that courts will not determine controversies where no actual relief can be granted or where a judgment would have no practical legal effect. The term of office for the position contested from the 1971 elections had already expired with the holding of the new election for municipal officials on January 30, 1980. Consequently, any judicial pronouncement on the correctness of the 1972 lower court decision would serve no useful purpose, as it could no longer restore the petitioner to the office in question. The Court cited its consistent rulings in analogous cases, such as Bitangcol vs. Court of Appeals and Abirin vs. COMELEC, which established the doctrine that election protests become moot upon the expiration of the contested term. Therefore, without reaching the substantive issue of ballot appreciation, the Court refrained from exercising its power of review, as the case no longer presented a justiciable controversy. No costs were awarded.