G.R. No. L-50917 August 29, 1980
TAS WORLD SHIPPING COMPANY, LTD. and NEW FILIPINO MARITIME AGENCIES, INC., petitioners, vs. MINISTER BLAS F. OPLE, NATIONAL SEAMEN BOARD and ESTRELLA BABAC, respondents.

FACTS

Petitioners Tas World Shipping Co., Ltd., a Japanese corporation, and New Filipino Maritime Agencies, Inc., a domestic corporation, filed this petition for certiorari to annul the March 5, 1979 decision of the National Seamen Board (NSB). The NSB had ordered the petitioners to pay respondent Estrella Babac the sum of Twenty Thousand Pesos (P20,000) as an additional death benefit, on top of an earlier award of Twelve Thousand Pesos (P12,000), in connection with the death of her son, Danny Babac, who was employed as a quartermaster on the petitioners’ vessel. The petitioners contested this additional liability imposed by the labor tribunal.
Subsequently, on June 18, 1980, Estrella Babac filed a verified motion to dismiss the case. She grounded her motion on the fact that her claim against the petitioners had already been fully satisfied through their payment to her of the original award of P12,000. Attached to her motion was a copy of a “Receipt and Quit-claim” she had executed upon receiving the payment. In their manifestation dated July 23, 1980, the petitioners concurred, stating that with such payment and the accompanying quitclaim, the instant petition had been rendered moot and academic.

ISSUE

Whether the petition for certiorari had been rendered moot and academic by the respondent-claimant’s receipt of payment and execution of a quitclaim for the original award.

RULING

Yes, the petition is dismissed for being moot and academic. The Supreme Court, through Justice Aquino, held that the supervening event—the payment of the original P12,000 award to Estrella Babac and her execution of a corresponding “Receipt and Quit-claim”—effectively extinguished the live controversy between the parties. When a claimant voluntarily accepts the benefits of an award and executes a quitclaim, she is deemed to have waived her right to pursue further claims related to the same subject matter, absent any showing that the waiver was vitiated by fraud, duress, or misrepresentation. No such vitiating circumstances were alleged or proven in this case.
Consequently, the core dispute over the propriety of the NSB’s additional P20,000 award lost its justiciable character. 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. The Court’s duty is to decide actual, ongoing controversies, not to rule on abstract questions or issue advisory opinions. Since the private respondent herself moved for dismissal based on satisfaction of her claim, and the petitioners agreed the case was moot, the Court had no remaining issue to adjudicate. The dismissal was thus proper, rendering any review of the NSB decision’s merits unnecessary. No costs were awarded.