G.R. No. L-25052 March 15, 1968
DATU MARIGA DIRAMPATEN, petitioner, vs. HON. HADJI MADKI ALONTO, personally and as PROVINCIAL GOVERNOR OF LANAO DEL SUR, THE PROVINCIAL BOARD OF LANAO DEL SUR, composed of HADJI MADKI ALONTO, as GOVERNOR, DATU MESUG CALACA as VICE GOVERNOR, DATU GASANARA LUCMAN and SHEIK ISMAEL LAUT as BOARD MEMBERS, SHEIK CAMPONG BASMAN as Officer-in-charge of the OFFICE OF THE PROVINCIAL GOVERNOR and HADJI ALIMODIN D. SUMPINGA, as VICE MAYOR of the Municipality of Taraka, respondents.

FACTS

On September 23, 1965, respondent Governor Hadji Madki Alonto of Lanao del Sur issued Administrative Order No. 2, suspending petitioner Datu Mariga Dirampaten from his office as Mayor of Taraka, Lanao del Sur, effective the following day. The suspension was pending an investigation by the provincial board concerning an administrative complaint against the petitioner for oppression, corruption, and maladministration. On the same date, the respondent Governor designated the respondent Vice-Mayor, Hadji Alimodin D. Sumpingan, as acting mayor for the duration of the suspension. On October 4, 1965, the petitioner filed a petition for certiorari, prohibition, and mandamus with preliminary mandatory injunction before the Supreme Court, seeking the annulment of the administrative order, a declaration of the illegality of the vice-mayor’s designation, an injunction against the provincial board’s investigation and the governor’s directive, an order for the governor to first conduct an investigation under Section 2188 of the Revised Administrative Code, and a preliminary mandatory injunction to restore him to his position. The Court issued the writ of preliminary mandatory injunction on October 6, 1965, upon the petitioner’s posting of a bond. The respondents filed their answer on November 23, 1965. During the general elections on November 14, 1967, the petitioner was re-elected as mayor. The respondents Alonto and Sumpingan did not run for re-election. On February 2, 1968, the petitioner filed a manifestation and motion to withdraw his petition, stating that the basic issue had been rendered moot and academic, supported by a COMELEC certification confirming his re-election and that Alonto and Sumpingan were not candidates in the 1967 elections.

ISSUE

Whether the petition has been rendered moot and academic by supervening events, specifically the re-election of the petitioner as mayor and the cessation from office of the principal respondents.

RULING

The Supreme Court granted the petitioner’s motion to withdraw the petition. The Court held that the supervening circumstances—the petitioner’s re-election as mayor and the fact that the principal respondents, Alonto (as Governor) and Sumpingan (as Vice-Mayor), had ceased to hold their respective offices—rendered the instant petition moot and academic for all practical purposes. The Court reasoned that with Alonto no longer Governor, he could not be bound by a decision in the case, and with Sumpingan no longer Vice-Mayor, the threat of his assuming the mayoralty vanished. An eventual resolution of the petition would serve no useful purpose given the present conditions of the parties. The Court noted that the petitioner himself sought the withdrawal and that any prejudice from the withdrawal would theoretically fall upon the petitioner, reverting him to his pre-injunction situation.