G.R. No. L-32221-38 April 27, 1972
Domingo Muñoz, et al., petitioners, vs. Hon. Agustin C. Bagasao, Judge, Court of Agrarian Relations, Third Regional District, Branch I, Lingayen, Pangasinan, The Court of Appeals and Juan T. Baun, respondents.

FACTS

The petitioners, claiming to be share tenants of respondent Juan T. Baun, filed multiple complaints in the Court of Agrarian Relations (CAR) for reliquidation of past harvests and a change to a leasehold system. Baun denied any tenancy relationship, asserting the petitioners were either relatives of previously ejected tenants or mere squatters, and that the lands had been under mechanized cultivation since 1953. The CAR dismissed the complaints in a joint decision dated June 28, 1969, ordering the petitioners’ ejectment and holding them liable for damages for filing the cases in bad faith. The petitioners perfected their appeal to the Court of Appeals on July 28, 1969.
Subsequently, the CAR, invoking Section 5 of Republic Act No. 5434 , issued an order on August 9, 1969, directing the immediate execution of its judgment despite the pending appeal, requiring Baun to post a bond. The CAR later issued orders for the petitioners to vacate after harvesting crops and, ultimately, to demolish their houses. The petitioners contested these orders before the Court of Appeals through motions to dissolve the writ of execution and for a restraining order, but these were denied. The petitioners then filed the instant petition for certiorari and prohibition with the Supreme Court, which issued a restraining order.

ISSUE

Whether the Supreme Court should resolve the procedural issues raised in the petition regarding the propriety of the execution pending appeal issued by the CAR.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic is grounded in the principle that courts will not determine questions that no longer present a justiciable controversy. While the petition originally challenged the CAR’s order for immediate execution pending appeal, the Court of Appeals had subsequently rendered a final and executory decision on August 9, 1971, affirming the CAR’s joint decision in its entirety. This final adjudication on the merits of the main cases rendered the procedural question on execution pending appeal stale and inconsequential.
The Court emphasized that adjudicating the procedural issues would be a “futile exercise in exegesis,” as the substantive rights of the parties had already been conclusively settled by the appellate court’s final judgment. The petitioners’ failure to comment on the respondent’s motion to dismiss based on this supervening event was construed as conformity. Consequently, the Court lifted the previously issued restraining order and dismissed the petition without costs, as no practical legal relief could be granted.