GR L 30418; (June, 1972) (Digest)
G.R. No. L-30418 June 15, 1972
PETRONILA REYES VDA. DE PIMENTEL and MARCIAL PIMENTEL, petitioners, vs. THE HONORABLE WALFRIDO DE LOS ANGELES, Judge of the Court of First Instance of Quezon City, SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, DIRECTOR OF FORESTRY and MARIA ROSARIO SY, respondents.
FACTS
Petitioners filed an action in the Court of First Instance seeking to annul the decision of the Secretary of Agriculture and Natural Resources, which awarded a timber license to private respondent Maria Rosario Sy. The respondent court dismissed the petition for lack of cause of action, ruling that petitioners had failed to exhaust administrative remedies as they still had a pending appeal before the Office of the President regarding the same award.
Petitioners then sought to appeal the trial court’s dismissal order. The respondent judge refused to give due course to the appeal, holding it was not perfected on time. This prompted petitioners to file the instant mandamus petition to compel the judge to allow their appeal.
ISSUE
Whether the petition for mandamus to compel the giving of due course to petitioners’ appeal has been rendered moot and academic.
RULING
Yes, the petition is moot and academic. The core legal logic is that supervening events have deprived the case of any justiciable controversy, rendering a ruling on the procedural issue of the appeal’s timeliness purely academic. After the trial court’s dismissal and during the pendency of this mandamus action, the Office of the President issued a decision on June 10, 1969, dismissing petitioners’ administrative appeal and affirming the award of the timber license to respondent Sy. A subsequent motion for reconsideration was denied on February 11, 1970.
Consequently, the substantive award challenged in the original court action has been definitively resolved by the highest administrative authority. Even if the Court were to grant the mandamus and allow the appeal from the trial court’s order, any judicial review would be futile. The trial court correctly dismissed the case for prematurity due to the pending administrative appeal; that administrative process has now concluded with a final decision against petitioners. Therefore, no practical legal purpose would be served by adjudicating the procedural question of whether the appeal was seasonably perfected, as the underlying dispute has been conclusively settled. The petition is dismissed for being moot.