G.R. No. 83092 October 5, 1989
LEONARDA T. AVEDANA, PURIFICACION T. TIMBANG, EMILIANA T. BAUTISTA and EVANGELINE BAUTISTA-ORTIZ, petitioners, vs. HON. COURT OF APPEALS, HON. JUDGE MANUEL P. DUMATOL, in his capacity as Presiding Judge of Regional Trial Court, Branch CXII, Pasay City, and MANOLITO N. BAUTISTA, respondents.

FACTS

Manuel Bautista owned a residential lot in Pasay City, a portion of which was leased indefinitely to petitioners Leonarda Avedana and Purificacion Timbang, who built a house thereon. Upon Manuel’s death, a dispute over ownership arose among his heirs. Private respondent Manolito Bautista, one of Manuel’s children from his first marriage, eventually acquired title and filed an ejectment case against the petitioners. The trial court ruled in Manolito’s favor, ordering the petitioners to vacate and demolish the house. This decision was affirmed by the Court of Appeals, albeit with a modification regarding indemnity under Article 1678 of the Civil Code.
Subsequent legal maneuvers by the petitioners, including a separate action to annul the ejectment judgment, were unsuccessful. The Supreme Court, in a prior related case, ultimately resolved the ownership issue in favor of Manolito. Consequently, the trial court granted Manolito’s motion for execution and a writ of demolition. The petitioners then filed this petition for certiorari to challenge the orders of the trial court and the Court of Appeals that upheld the execution and demolition.

ISSUE

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

RULING

Yes, the petition is dismissed for being moot and academic. The Supreme Court found that during the pendency of this petition, the house constructed by petitioners Avedana and Timbang on the leased premises had already been demolished in the latter part of 1988, and they had vacated the property. Furthermore, the core issue of ownership, which was the foundational dispute prompting the ejectment and execution proceedings, had been conclusively resolved by the Court in a separate related case, G.R. No. 79958. The legal logic is clear: courts will not determine cases where no actual substantial controversy exists or where the events have so overtaken the proceedings that a judicial declaration would have no practical legal effect. When the subject of the action, such as the possession of a property or the existence of a structure sought to be demolished, has been irreversibly altered (e.g., by vacation and demolition), and the underlying substantive rights have been adjudicated in a final ruling, the case is deemed moot. Judicial resources are not expended on abstract questions, and the petition is therefore dismissed.