TAMDA SERVICE COOPERATIVE, INC., petitioner, vs. THE CITY MAYOR AND THE CITY TREASURER OF TACLOBAN CITY, and THE COURT OF FIRST INSTANCE OF LEYTE, respondents.
FACTS
The petitioner, TAMDA Service Cooperative, Inc., filed a petition for review by certiorari to challenge the judgment of the Court of First Instance of Leyte. The lower court had dismissed the cooperative’s action for mandamus, which sought to compel city officials to recognize its right to operate. The dismissal was based on the court’s agreement with a prior opinion from the Secretary of Justice. That opinion stated that organizing a cooperative for the purpose of operating motor vehicles for hire as a common carrier was alien to the nature and purposes of cooperatives as contemplated under Republic Act No. 2023, the Non-Agricultural Cooperative Act. Consequently, the lower court ruled that both the Cooperatives Administration Office, in registering the entity, and the Public Service Commission, in granting it a franchise, had committed legal error.
While the petition was pending before the Supreme Court, the respondents filed a manifestation seeking its dismissal. They argued the case had become moot and academic. They presented certifications indicating the petitioner had failed to comply with the requirements of Presidential Decree No. 175 by not submitting necessary financial statements and meeting minutes to the supervising government agency. Furthermore, the petitioner’s Certificate of Public Convenience, issued by the Public Service Commission, had already expired and was not renewed. The respondents contended that the cooperative had therefore ceased to exist as a legal entity and as an authorized operator.
ISSUE
Whether or not the petition for review had become moot and academic, thereby warranting its dismissal.
RULING
Yes, the Supreme Court dismissed the petition as moot and academic. The legal logic is grounded in the principle that courts will not adjudicate cases where no actual, substantial controversy exists or where the issues have been rendered academic by subsequent events. For a court to exercise its power of judicial review, there must be an existing case or controversy at all stages of review, not merely when the action is initiated.
The Court found merit in the respondents’ contention based on the petitioner’s own admissions. The petitioner conceded its failure to submit the required reports to the Ministry of Local Government and Community Development and admitted its failure to renew its expired franchise with the Public Service Commission. These admissions were decisive. The failure to comply with the mandatory reporting requirements under P.D. No. 175, which governed cooperatives, and the lapse of its operating franchise meant the petitioner had effectively lost its legal standing. It was no longer a duly registered cooperative entity authorized to operate as a common carrier.
Since the petitioner had ceased to exist in the eyes of the law for the purposes of its cooperative status and its franchise to operate, any judicial pronouncement on the substantive issue-whether a cooperative could legally operate as a common carrier under R.A. No. 2023-would be ineffectual. A favorable ruling could no longer be enforced or executed, as there was no longer a legal entity to which relief could be granted. Therefore, the underlying controversy was extinguished, and the petition was dismissed for being moot.
