G.R. No. L-30615 and G.R. No. L-34475. January 31, 1983.
ANCHORAGE WOOD INDUSTRIES, INC., petitioner, vs. BISLIG BAY LUMBER CO., INC. and JUDGE JESUS P. MORFE, Branch XIII, Court of First Instance of Manila, respondents. BISLIG BAY LUMBER CO., INC., petitioner, vs. COURT OF APPEALS, JUDGE GUARDSON R. LOOD, Court of First Instance of Rizal and ANCHORAGE WOOD INDUSTRIES, INC., respondents.

FACTS

Bislig Bay Lumber Co., Inc. (now Paper Industries Corporation of the Philippines) filed Civil Case No. 75120 in the Court of First Instance (CFI) of Manila on December 16, 1968. The action sought to enjoin the implementation of a November 19, 1968 order by the Director of Forestry, which declared the “Bernardo Line” as the correct boundary between the timber concessions of Bislig and Anchorage Wood Industries, Inc. in Agusan, and to enjoin Anchorage and Eastcoast Development Enterprises from encroaching on Bislig’s concession. Judge Jesus P. Morfe issued an order on May 21, 1969, enjoining Anchorage and Eastcoast from logging in the disputed area. Anchorage assailed this order before the Supreme Court via a petition for certiorari and prohibition, docketed as G.R. No. L-30615.
Subsequently, on July 4, 1969, the Secretary of Agriculture rendered a decision on the boundary dispute, declaring the “Genio Line” as the correct boundary. Anchorage appealed to the Office of the President, which affirmed the Secretary’s decision on May 5, 1970. Anchorage then filed a separate petition for certiorari and prohibition in the CFI of Rizal (Civil Case No. 14393) on February 12, 1971, seeking to annul the Presidential decision and insisting on the Bernardo Line. Judge Guardson R. Lood denied Bislig’s motion to dismiss this petition. Bislig questioned this denial before the Court of Appeals, which affirmed Judge Lood’s order. Bislig then appealed this appellate decision to the Supreme Court, docketed as G.R. No. L-34475, which was consolidated with L-30615.

ISSUE

Whether the consolidated petitions before the Supreme Court have been rendered moot and academic.

RULING

Yes, the cases are moot and academic. The legal logic is grounded in the principle that courts will not determine questions that no longer present a justiciable controversy because the issues have been resolved or have ceased to exist. The root of G.R. No. L-30615 was the injunction order issued in Civil Case No. 75120 by the CFI of Manila. On February 2, 1976, that very civil case was dismissed by the CFI of Manila at Bislig’s instance, without objection from Anchorage or the Director of Forestry, on the ground that it had become moot and academic. Consequently, Anchorage moved to dismiss its own petition in L-30615, as the foundation case had been terminated.
Bislig’s failure to comment on Anchorage’s motion to dismiss despite being required by the Court, which the resolution deemed censurable, further indicated the absence of a live dispute requiring adjudication. With the dismissal of the originating civil case, the propriety of the injunction order challenged in L-30615 was rendered abstract. The interrelated nature of the consolidated cases meant the mootness of the primary case extinguished the practical legal effects of the ancillary proceedings. Therefore, the Supreme Court dismissed both consolidated cases for having become moot and academic.