G.R. No. L-33445 December 28, 1972
MANUEL P. SANTOS and RUBEN P. BERNARDO, petitioners, vs. THE HONORABLE JUDGE PEDRO JL. BAUTISTA, et al., respondents.

FACTS

Petitioners Manuel P. Santos and Ruben P. Bernardo filed a petition for certiorari, prohibition, and mandamus seeking to nullify an order of respondent Judge Pedro JL. Bautista. The order sustained the CFI’s jurisdiction to hear a petition for review of a decision and decree of registration issued in favor of the petitioners in a prior land registration case, LRC No. PN-101. This prior case was heard by the municipal judge of Parañaque upon delegation, as the land’s assessed value was below P10,000. The private respondents (the Cruz family), who were oppositors in that registration case, argued before the CFI that the municipal judge lacked jurisdiction because the land’s actual value in 1966 was substantial, allegedly around P750,000, and that related cases (a civil case for recovery of possession and another land registration case) were already pending before the CFI.
Subsequently, during the pendency of the certiorari petition before the Supreme Court, all parties involved sold their respective rights and interests in the disputed land to a single third party, Mariano Z. Velarde. Petitioner Ruben P. Bernardo executed a deed of absolute sale with mortgage in February 1972, and petitioner Manuel P. Santos conveyed his rights in October 1972. The private respondents also agreed to sell their rights to Velarde and accordingly filed a motion to withdraw their petition for review in the lower court. Given these transfers, the parties jointly petitioned the Supreme Court to dismiss the case as moot.

ISSUE

Whether the petition for certiorari challenging the CFI’s jurisdiction over the petition for review has been rendered moot and academic by the subsequent sale of all conflicting interests in the subject land to a single purchaser.

RULING

Yes, the petition is dismissed as moot and academic. The core legal principle applied is that courts will not determine a question where no actual controversy exists or where the issues have ceased to be justiciable. The petition sought to prevent the CFI from reviewing the land registration decree. However, the supervening event—the conveyance of all rights, interests, and participations of both the petitioners and the private respondents to one and the same person, Mariano Z. Velarde—has fundamentally altered the situation. The original dispute between the parties over the land’s registration and ownership has been extinguished. With all adverse claims consolidated in a single owner, there remains no live controversy for the Court to adjudicate regarding the CFI’s jurisdiction. A ruling on the procedural issue of which court had authority to review the decree would serve no practical or useful purpose, as it would not affect the rights of the original parties, who have all divested their interests. The dismissal is without prejudice to the right of the petitioners’ original counsel to pursue appropriate action to protect their claimed attorney’s fees.