G.R. No. L-20304; October 30, 1964
Perfecto Faypon, petitioner, vs. Salvador L. Mariño, Felicisimo R. Rosete and Alejandro E. Sebastian, respondents.

FACTS

Petitioner Perfecto Faypon, the Director of the Philippine Virginia Tobacco Administration, was suspended from his office by an order of the Executive Secretary dated September 6, 1962, pending an administrative investigation of charges filed against him. He filed a petition with the Supreme Court seeking the annulment of that suspension order, his reinstatement, and an injunction to stop the administrative proceedings. On December 21, 1962, the Supreme Court granted his plea for a mandatory injunction and ordered his immediate reinstatement. The Court found his three-and-a-half-month suspension to have become unreasonable, noting that the investigation did not appear to have progressed during that period and that his fixed term of office was set to expire on January 3, 1963.
The administrative investigation against Faypon was subsequently concluded on May 10, 1963. However, a critical development occurred: Faypon’s term of office expired on January 3, 1963, as admitted by the parties, and he was not reappointed to the position. This expiration of his term transpired after the Court’s reinstatement order but before the final resolution of his petition challenging the validity of his suspension.

ISSUE

The primary issue is whether the petition for annulment of the suspension order and for reinstatement retains any justiciable controversy, or if it has been rendered moot and academic by the expiration of the petitioner’s term of office.

RULING

The Supreme Court dismissed the case as moot and academic. The legal logic is grounded in the principle that courts will not adjudicate cases where no actual substantial controversy exists between parties, or where the issues have ceased to be live. The core reliefs sought by Faypon—the annulment of his suspension and his restoration to the office—were predicated on his occupancy of the position of Director. His legal right to hold that office was defined and limited by a fixed term ending on January 3, 1963.
Upon the expiration of that term without renewal of his appointment, Faypon ceased to have any present, enforceable legal right to the office. Consequently, any judicial declaration on the legality of his prior suspension would be ineffectual, as it could not restore him to a position he no longer had a claim to. The termination of the administrative case also removed any ancillary issue regarding the proceedings. Since no practical legal relief could be granted, the Court was precluded from making a determination on the merits. The resolution of mootness is procedural but fundamental, ensuring judicial resources are devoted to active disputes affecting the rights of the parties.