G.R. No. L-27566. October 14, 1975.
HON. ANTONIO RAQUIZA, as Secretary of Public Works and Communications; BALTAZAR AQUINO, as Commissioner of Public Highways, and J. B. TAGORDA, as Division Engineer, 9th Engineering Division, Bureau of Public Highways, petitioners, vs. CITY OF MANILA, HON. ANTONIO VILLEGAS, as Mayor of the City of Manila; LADISLAO J. TOLENTINO, as City Engineer of Manila, and HON. HILARION U. JARENCIO, as Presiding Judge of Branch XXIII of the Court of First Instance of Manila, respondents.

FACTS

The case originated from a dispute between national government officials and the City of Manila regarding the authority to undertake and fund the improvement of Harrison Boulevard. The petitioners, the Secretary of Public Works and Communications, the Commissioner of Public Highways, and a Division Engineer, filed special actions for prohibition and certiorari with the Supreme Court. They sought to nullify an order dated May 12, 1967, issued by the Court of First Instance of Manila in Civil Case No. 67867. That lower court order directed the national officials to release the sum of P815,000 to the City of Manila as its allocation for the project, to allow the city to undertake the improvement, and to cease their own ongoing project for the same thoroughfare.
The legal conflict centered on the interpretation of statutes governing jurisdiction over roads. The national officials premised their petition on Republic Acts Nos. 917 and 1192, in relation to section 79(C) of the Revised Administrative Code, asserting that the Secretary had supervision and control over national roads within Manila, limiting the city’s jurisdiction to projects financed solely with city funds. Conversely, the respondent city officials contended that Harrison Boulevard was a city street and that the undertaking of such projects in Manila was vested in the City Engineer, albeit under the administrative supervision of the Bureau of Public Highways.

ISSUE

Whether the Supreme Court could render a substantive ruling on the jurisdictional dispute between the national government and the City of Manila over the improvement of Harrison Boulevard.

RULING

The Supreme Court dismissed the case as moot and academic. In a resolution dated September 3, 1975, the Court took judicial notice that Harrison Boulevard had already been improved and required the parties to manifest whether the case had thereby become moot. Both parties, through the Acting Solicitor General for the petitioners and the respondents themselves, submitted manifestations agreeing that the case was indeed moot. The petitioners confirmed that the sum of P815,000 had already been released and expended for the improvement of Harrison Boulevard under the administration of the Bureau of Public Highways. Since the very subject matter of the controversy—the improvement project and the release of funds—had been fully accomplished, no justiciable issue remained for judicial resolution. The Court, therefore, refrained from deciding the underlying legal question regarding the allocation of administrative authority and control over the roadway. The petition was dismissed without costs.