G.R. No. L-21159 July 25, 1979
BACNOTAN CEMENT INDUSTRIES, INC., and RAFAEL GALVEZ, petitioners-appellants, vs. THE HONORABLE COURT OF APPEALS, HON. FELICIANO BELMONTE and HON. JOSE P. FLORES, in their capacity as Judges of the Court of First Instance of La Union, the REPUBLIC OF THE PHILIPPINES and the SHERIFF OF LA UNION or any of his Deputies, respondents-appellees.

FACTS

This petition for certiorari originated from a preliminary and mandatory injunction issued by then respondent Judge Jose P. Flores in Land Registration Case No. N-361. The injunction enjoined petitioners Rafael Galvez and his lessee, Bacnotan Cement Industries, Inc., from removing or demolishing a fence on a property and ordered them to restore any removed parts. The Republic of the Philippines had filed a motion to cancel Galvez’s Original Certificate of Title No. O-381, alleging the land was within the Camp Wallace Military Reservation and had been registered in favor of the United States Government as early as 1906. Petitioners’ motion to dissolve the injunction was denied by Judge Feliciano Belmonte. The Court of Appeals subsequently dismissed their petition for certiorari, prompting this appeal to the Supreme Court.
During the pendency of this appeal, significant developments occurred in the main case. The Court of First Instance of La Union, in an order dated February 1, 1963, declared the proceedings in Land Registration Case No. N-361 and the resulting title in Galvez’s name null and void, ordering its cancellation. This order was affirmed by the Court of Appeals in a decision dated August 14, 1973, which became final and executory. A writ of execution was subsequently issued to implement these orders and the appellate decision.

ISSUE

Whether the petition for certiorari assailing the issuance of the preliminary injunction has been rendered moot and academic.

RULING

Yes, the petition is moot and academic. The Supreme Court dismissed the petition on this ground. The core legal logic is that courts will not determine cases where no actual controversy exists or where the issues have ceased to be justiciable. A case becomes moot when it no longer presents a live, concrete dispute requiring resolution, or when a judgment would not provide any actual relief or have any practical legal effect.
Here, the petition challenged only the propriety of the preliminary injunction, which was an ancillary remedy issued during the pendency of the main action concerning the validity of Galvez’s title. The main case has been conclusively adjudicated with a final and executory judgment declaring Galvez’s title null and void. Consequently, the preliminary injunction, which was merely a provisional measure to preserve the status quo pending litigation, has been superseded by this final judgment on the merits. Any ruling by the Supreme Court on the injunction would be an academic exercise, as the substantive rights of the parties have already been definitively settled. The Court therefore refrained from rendering a decision on a matter that would serve no useful purpose.