G.R. No. L-30793-94 July 30, 1979
MISAEL P. VERA, as Commissioner of Internal Revenue, and THE FAIR TRADE BOARD, petitioners, vs. HON. SERAFIN R. CUEVAS, as Judge of the Court of First Instance of Manila, Branch IV, INSTITUTE OF EVAPORATED FILLED MILK MANUFACTURERS OF THE PHILIPPINES, INC., et al., respondents.
FACTS
This petition for certiorari and prohibition sought to annul the writs of preliminary injunction issued by the Court of First Instance (CFI) of Manila in two consolidated cases. In the first case (Civil Case No. 52276), respondent milk manufacturers sued to enjoin the Commissioner of Internal Revenue from enforcing Section 169 of the Tax Code, which required them to print on their filled milk product labels the warning: “This milk is not suitable for nourishment for infants less than one year of age.” In the second case (Special Civil Action No. 52383), the same manufacturers sought to enjoin the Fair Trade Board from proceeding with complaints against them for alleged mislabeling or misbranding of these milk products.
The CFI, proceeding with the cases as no restraining order was issued by the Supreme Court in this petition, eventually rendered a decision on the merits. It perpetually restrained the Commissioner of Internal Revenue from enforcing the labeling requirement and declared the related administrative orders null and void. It also perpetually restrained the Fair Trade Board from continuing its investigation into the misbranding complaints and nullified all proceedings already undertaken.
ISSUE
Whether the petition for certiorari and prohibition filed by the Commissioner of Internal Revenue and the Fair Trade Board, seeking to set aside the CFI’s preliminary injunctions, has been rendered moot and academic.
RULING
Yes, the petition is moot and academic. The legal logic is straightforward: the supervening event of a final judgment by the Supreme Court on the very subject matter of the petition has deprived it of any justiciable controversy. The CFI’s decision, which granted permanent injunctive relief, was elevated to the Supreme Court via a separate petition for review (G.R. No. L-33693-94). In a decision promulgated on May 31, 1979, the Supreme Court affirmed the CFI’s judgment. Consequently, the preliminary injunctions, which were merely interim measures, merged into and were superseded by the final and affirmed permanent injunctions. The present petition, which only challenged these interim orders, no longer presents an active case or controversy. There is no longer any effective relief that the Court can grant, as the substantive rights of the parties have already been conclusively adjudicated in the affirmed decision. When a case loses its adversarial character and a ruling on the merits would be of no practical value, the court must dismiss it for being moot. Accordingly, the petition is dismissed.