G.R. No. L-33090 December 29, 1972
LAWYERS LEAGUE FOR BETTER PHIL., AND/OR OLIVER O. LOZANO, petitioners, vs. NATIONAL PRICE CONTROL COUNCIL AND/OR SHELL PHILIPPINES, INC., CALTEX PHILIPPINES, INC., FILOIL REFINERY CORPORATION, MOBIL OIL PHILIPPINES, INC., GETTY OIL PHILIPPINES, INC., ESSO PHILIPPINES, INC., respondents.

FACTS

The petitioners filed a petition for certiorari with a prayer for a preliminary injunction seeking to nullify an order dated January 28, 1971, issued by the National Price Control Council, which fixed the prices of various petroleum products. The core legal controversy pertained to the validity of this price-fixing order. In response, this Court issued a resolution on July 6, 1971, commanding the respondent oil companies to desist from enforcing any price increases and to maintain prices at the levels set in the Council’s January order.
Subsequently, a significant legislative development occurred. On July 27, 1971, Republic Act No. 6361 , known as the New Price Control Law, was approved. This new law expressly included “fuels, lubricants, crude oil and petroleum products” among the essential commodities subject to price control. Crucially, Section 3 of this law provided that the maximum prices established and enforced as of June 30, 1971—which were the very prices set by the challenged January 28 order—would remain effective. Based on this enactment, all respondent oil companies filed motions to dismiss the petition, arguing it had become moot and academic.

ISSUE

Whether the petition for certiorari assailing the Price Control Council’s January 28, 1971 order has been rendered moot and academic by the passage of Republic Act No. 6361 (the New Price Control Law).

RULING

Yes, the petition is moot and academic. The Court granted the motions to dismiss. The legal logic is grounded in the doctrine of mootness, which dictates that courts will not determine cases where no actual controversy exists or where the issues have ceased to be justiciable. The enactment of Republic Act No. 6361 fundamentally altered the legal landscape. The new statute did not merely reauthorize price control; it specifically provided that the price ceilings enforced as of June 30, 1971—the same ceilings established by the now-challenged January 28 order—were to be maintained by operation of law. Therefore, the legal force of the price levels no longer derived solely from the Council’s disputed order but from a direct statutory mandate. Any judicial declaration on the validity of the Council’s old order would have no practical legal effect, as the prices were preserved by the new law. Furthermore, the Court noted that the substantive issue of appropriate price levels for petroleum products had been transferred to a new forum: the Oil Industry Commission, which had begun hearings on the matter, with its determinations already the subject of separate pending petitions for review before the Court. Thus, the specific case was dismissed for being moot.