G.R. No. L-25271. May 31, 1982. THE REPARATIONS COMMISSION, petitioner, vs. HON. GUILLERMO SANTOS, as Judge of the Court of First Instance of Manila, and GIL J. PUYAT, personally and in his capacity as President of the Nacionalista Party, respondents.
FACTS

Respondent Gil J. Puyat filed a petition for certiorari, prohibition, and mandamus in the Court of First Instance of Manila against the Reparations Commission. He sought to annul a Commission resolution approving a reparations contract with Toyo Trading Co., Ltd. for firefighting equipment and a related inspection contract. Puyat also sought to prohibit the Commission from proceeding with these contracts and to compel compliance with the Reparations Law. The lower court issued a writ of preliminary injunction and a subsequent supplemental writ, ordering the Commission to refrain from implementing the contracts and to secure the return of a 30% advance payment made to the Japanese supplier.
The Reparations Commission petitioned the Supreme Court to question the propriety of these injunctive writs. The Supreme Court, in a resolution, advised the Commission to seek relief in the lower court which had full cognizance of the facts. Following this, the Commission filed an urgent motion in the lower court to dissolve the writs, arguing that the Philippine Mission’s refusal to accept delivery due to the injunction had resulted in substantial and increasing storage charges potentially liable to the Republic of the Philippines and was damaging to the country’s prestige. The lower court granted the motion and dissolved both the original and supplemental writs of preliminary injunction.

ISSUE

Whether the Supreme Court should rule on the propriety of the now-dissolved writs of preliminary injunction issued by the lower court.

RULING

The Supreme Court dismissed the petition for being moot and academic. The core legal principle applied is that courts will not determine questions that no longer present an actual, live controversy. A case becomes moot when there is no more actual relief that the petitioner can seek or when the acts sought to be enjoined have already been accomplished or ceased to exist. Here, the very subject of the Commission’s petition—the writs of preliminary injunction—had already been dissolved by the lower court upon the Commission’s own motion. Consequently, the injunction orders that the Commission sought to nullify were no longer in effect. The Supreme Court found that with the dissolution of these injunctive writs, the petition lost its practical purpose and presented no justiciable controversy requiring adjudication. The Court therefore refrained from rendering a decision on the merits of the propriety of the issuance of the writs, as such a ruling would be an abstract declaration without legal force or practical value. The dismissal was without costs.