G.R. No. L-26759 August 23, 1974
MANILA ELECTRIC COMPANY, petitioner, vs. ENRIQUE MEDINA, Public Service Commissioner, MANUEL MADRIGAL, JOSUE JAVELLANA (Mrs.) and BRIGIDO SEDENIO, respondents.

FACTS

The petitioner, Manila Electric Company (MERALCO), filed a petition for prohibition seeking to enjoin Public Service Commissioner Enrique Medina from further presiding over PSC Case No. 65-4206-C. The sole ground for the petition was the alleged “very strained relations” between Commissioner Medina and MERALCO’s counsel, Atty. Vicente J. Francisco. MERALCO argued this relationship compromised the Commissioner’s impartiality, warranting his inhibition from the case.
The case originated from a restraining order issued by Commissioner Medina on September 10, 1965, which prohibited MERALCO from disconnecting electrical services to certain consumers during the pendency of the commission case. After filing a motion to lift this order, MERALCO subsequently filed a motion for Commissioner Medina’s inhibition. The Commissioner denied this motion. MERALCO’s counsel then filed a second, more detailed motion for inhibition, which the Commissioner treated as an untimely motion for reconsideration and likewise denied.

ISSUE

Whether the petition for prohibition, seeking to compel Commissioner Enrique Medina to inhibit himself from PSC Case No. 65-4206-C due to alleged strained relations with a party’s counsel, retains any justiciable merit.

RULING

The Supreme Court dismissed the petition as moot and academic. The legal logic for dismissal rests on the principle that courts will not determine cases where no actual controversy exists or where the issues have been rendered academic by supervening events. The Court took judicial notice of several decisive factual developments that eliminated the live dispute. First, the Public Service Commission itself, the tribunal in question, had been abolished and replaced by the Board of Transportation. Second, the specific respondent official, Commissioner Enrique Medina, had already retired from government service. Third, the petitioner’s counsel, Atty. Vicente J. Francisco, whose personal relationship with the Commissioner was the foundational basis for the entire petition, was deceased. Consequently, the relief sought—to prohibit a retired official from acting in a case before a defunct commission—was impossible to grant and presented no ongoing legal controversy requiring adjudication. The Court therefore refrained from examining the substantive merits of the allegations of bias, as any ruling thereon would have no practical legal effect. The petition was dismissed without costs.