GR 48678; (August, 1980) (Digest)
G.R. No. L-48678 August 21, 1980
Arnedo S. Lucas and Benjamin S. Lucas, petitioners, vs. Hon. Court of Appeals, Hon. Fernando A. Cruz, as Presiding Judge of the Court of First Instance of Rizal, Caloocan City Branch XII, Rufina & Company and Jesus S. Lucas, respondents.
FACTS
Petitioners Arnedo S. Lucas and Benjamin S. Lucas appealed from a Court of Appeals decision that sustained a trial court order. The trial court, presided by Judge Fernando A. Cruz, had denied their motion to dismiss a complaint for specific performance and damages filed by their brother, respondent Jesus S. Lucas, and the firm Rufina & Company. The motion to dismiss was grounded on the claim that the action, involving relations among partners of Rufina & Company, fell under the exclusive jurisdiction of the Securities and Exchange Commission pursuant to Sections 5 and 6 of Presidential Decree No. 902-A.
The Supreme Court gave due course to the appeal, and the parties filed their briefs. The Court also invited the SEC’s Legal Counsel and the Solicitor General to intervene as amici curiae. However, during the pendency of the appeal, petitioner Arnedo S. Lucas withdrew his appeal, which the Court allowed in a resolution dated March 28, 1980.
ISSUE
Whether the appeal should be dismissed on the ground of mootness due to a supervening amicable settlement between the parties.
RULING
Yes, the appeal is dismissed for being moot and academic. The legal logic is grounded in the principle that courts will not determine questions that no longer present a justiciable controversy because the issues have been resolved by subsequent events. A case becomes moot when there is no more actual controversy between the parties or no useful purpose can be served by a judicial pronouncement.
Here, a supervening event rendered the core jurisdictional issue academic. Initially, the petitioners contested the trial court’s jurisdiction, arguing the SEC had exclusive authority over intra-partnership disputes. However, during the Supreme Court’s deliberation, both petitioners entered into amicable settlements with the respondents. First, Arnedo Lucas withdrew his appeal, which the Court permitted. Subsequently, Benjamin Lucas, through a joint manifestation and motion to dismiss filed with respondent Jesus Lucas and Rufina & Company, confirmed he had also reached an amicable settlement. With all parties having settled their dispute, the original conflict that gave rise to the appeal over the denial of the motion to dismiss ceased to exist. Consequently, any ruling on the jurisdictional question between the regular courts and the SEC would be an advisory opinion without practical legal effect. The Court, therefore, dismissed the case.