G.R. No. L-19733, November 28, 1964
ARSENIO L. CANLAS and ADENA GONZALES-CANLAS, petitioners, vs. THE JUDGE OF THE COURT OF FIRST INSTANCE OF TARLAC and JAIME TAYAG, respondents.

FACTS

The spouses Arsenio L. Canlas and Adena Gonzales-Canlas (petitioners) filed Civil Case No. 3512 before the Court of First Instance (CFI) of Tarlac to enjoin respondent Jaime Tayag from constructing and operating a rice mill in front of their clinic and private hospital. The then presiding Judge, Zoilo Hilario, granted their prayer and issued a writ of preliminary injunction. Subsequently, Tayag filed a petition to dissolve the injunction. Judge Bernabe de Aquino, who later took over the case, granted Tayag’s petition and dissolved the preliminary injunction. The spouses Canlas moved for reconsideration, but it was denied. They then elevated the matter to the Supreme Court via a petition for certiorari (G.R. No. L-16815).
In G.R. No. L-16815, the Supreme Court, in a decision promulgated on July 24, 1961, annulled the CFI’s order dissolving the preliminary injunction. The Court found that Tayag’s petition for dissolution was not verified and was granted without a hearing, based merely on information that the rice mill would not constitute a nuisance. The Supreme Court reinstated the preliminary injunction, emphasizing that allowing the construction to proceed would render the main action futile and cause irreparable harm to the hospital’s operations and patients.
Following the Supreme Court’s decision, the case was remanded to the CFI. Tayag then filed a new, alternative petition in the lower court, again seeking to lift the writ of preliminary injunction. This new petition rectified the earlier procedural defects and was supported by affidavits. On October 14, 1961, the CFI, acting on this renewed petition, issued an order dissolving the preliminary injunction for the second time. The spouses Canlas again came to the Supreme Court via the present petition for certiorari (G.R. No. L-19733), arguing that this second dissolution order contravened the Supreme Court’s prior decision in G.R. No. L-16815 and amounted to a prejudgment of the case on the merits. The Supreme Court issued a preliminary injunction in this certiorari proceeding to enjoin the enforcement of the CFI’s October 14, 1961 order.
During the pendency of this certiorari case, the CFI rendered a final decision on the merits in Civil Case No. 3512, dismissing the spouses Canlas’s main petition and consequently dissolving the preliminary injunction issued therein. Tayag then moved to lift the preliminary injunction issued by the Supreme Court in the instant certiorari case, citing the CFI’s final decision. The spouses Canlas objected, noting they had appealed the CFI’s decision to the Court of Appeals.

ISSUE

Whether the Supreme Court should resolve the merits of the petition for certiorari (G.R. No. L-19733) challenging the CFI’s second order dissolving the preliminary injunction, in light of the CFI’s subsequent rendition of a final decision on the merits in the main case.

RULING

The Supreme Court dismissed the petition for certiorari as moot and academic and dissolved the preliminary injunction it had issued in this proceeding.
The Court clarified the nature and purpose of its prior decision in G.R. No. L-16815 and the injunction issued in the present case. The decision in G.R. No. L-16815 merely annulled the CFI’s first dissolution order due to procedural infirmities (an unverified petition granted without a hearing) and because the circumstances at that time did not justify dissolution. That decision effectively reinstated the preliminary injunction only until the main case could be finally heard and decided on the merits. It did not perpetually enjoin the CFI from ever dissolving the injunction; it only corrected a specific erroneous order.
When the CFI, upon a new and proper petition from Tayag, issued its second dissolution order on October 14, 1961, the spouses Canlas challenged it in this separate certiorari proceeding (G.R. No. L-19733). The preliminary injunction issued by the Supreme Court in this case was intended solely to maintain the status quo and prevent the enforcement of that specific October 14, 1961 CFI order while this certiorari petition was being resolved.
The pivotal development was the CFI’s rendition of a final decision on the merits in the main case (Civil Case No. 3512), which dismissed the spouses Canlas’s complaint and dissolved the preliminary injunction issued therein. The Supreme Court held that this event rendered the present certiorari petition academic. The core issue—the propriety of the CFI’s October 14, 1961 interlocutory order dissolving the preliminary injunction pending trial—was superseded by the final judgment. The purpose of the Supreme Court’s preliminary injunction in this certiorari case (to preserve the status quo pending review of the dissolution order) was thereby achieved, or more precisely, became functus officio. The main case having been decided, there was no longer any preliminary injunction from the main case to be preserved or dissolved via the challenged interlocutory order. Consequently, there was no live controversy for the Supreme Court to adjudicate in this certiorari proceeding. The proper recourse for the spouses Canlas was to pursue their appeal on the merits of the main case before the Court of Appeals.