G.R. No. L-38502 March 25, 1975
HON. PIO B. FERANDOS, petitioner, vs. HON. JUAN Y. REYES, LEOCADIO VERDEFLOR and ATTY. MARCIAL A. EDILLON, respondents.

FACTS

Judge Pio B. Ferandos of the Court of First Instance (CFI) of Cebu, Branch IX at Toledo City, issued an order in Civil Case No. 150-T dismissing plaintiff Leocadio Verdeflor’s complaint for non-appearance at pre-trial and subsequently rendered an amended decision against Verdeflor. After the denial of his motion for reconsideration, Verdeflor filed a notice to appeal by writ of certiorari to the Court of Appeals, which dismissed the appeal for non-compliance with procedural rules. Subsequently, on January 29, 1974, Verdeflor and his counsel, Atty. Marcial A. Edillon, filed a separate action for damages and annulment of judgment (Civil Case No. R-13779) before the CFI of Cebu, Branch I, presided by Judge Juan Y. Reyes, naming Judge Ferandos (in his official capacity) and the opposing party as defendants. The complaint alleged that Judge Ferandos had previously announced his inhibition in cases involving Atty. Edillon, which led to their non-appearance at the pre-trial.
Judge Ferandos moved to dismiss the complaint against him, invoking judicial immunity for acts done in the exercise of judicial functions. Judge Reyes denied the motion to dismiss and a subsequent motion for reconsideration. Consequently, Judge Ferandos filed the instant special civil actions of certiorari, mandamus, and prohibition before the Supreme Court to challenge Judge Reyes’s denial. However, during the pendency of this petition, Verdeflor filed a motion in Civil Case No. R-13779 to strike out his name as co-plaintiff, admitting he had no cause of action for damages against Judge Ferandos. Judge Reyes granted the motion and dismissed the complaint, reserving the defendants’ right to prove their counterclaims.

ISSUE

Whether the instant special civil actions filed by Judge Ferandos have been rendered moot and academic by the dismissal of the underlying civil case for damages against him.

RULING

Yes, the petition is dismissed for being moot and academic. The core legal principle is that courts will not determine cases where no actual controversy exists or where the issues have become academic. The factual development during the pendency of the petition fundamentally altered the justiciable controversy. Judge Reyes’s order of July 26, 1974, dismissed Civil Case No. R-13779 upon Verdeflor’s own motion, wherein Verdeflor expressly admitted having no cause of action against Judge Ferandos. This dismissal removed the very subject matter of the petition—the challenged orders denying the motion to dismiss. With the main action against Judge Ferandos terminated, there was no longer any actual grievance or relief that could be granted through the extraordinary writs sought. The petitioner himself, through counsel, conceded this point by manifesting to the Court that the case had become “ipso facto moot and academic.” Consequently, the Supreme Court dismissed the petition, as any ruling on the propriety of Judge Reyes’s earlier interlocutory orders would be an advisory opinion on a ceased dispute, which is outside the Court’s constitutional mandate. No costs were awarded.