GR L 40143; (May, 1975) (Digest)
G.R. No. L-40143 May 12, 1975
MARIANO G. HIQUIANA, petitioner, vs. COMMISSION ON ELECTIONS, HON. JOSE A. RONO, as Secretary of the Department of Local Government and Community Development, and DANIEL SAKAY, respondents.
FACTS
Petitioner Mariano G. Hiquiana was the duly elected barrio captain of Santol, Quezon City in 1972. In December 1973, private respondent Daniel Sakay was appointed by the Quezon City Mayor to replace him. Hiquiana filed a quo warranto case before the Quezon City Court of First Instance (CFI) challenging Sakay’s appointment and secured a writ of preliminary injunction on January 31, 1974, which enjoined Sakay from discharging the duties of barrio captain and ordered the status quo maintained.
Subsequently, on May 1, 1974, Sakay obtained a separate appointment from President Marcos as Zone Chairman of the same area. When the Commission on Elections (COMELEC) conducted the registration of barangay members for the national referendum scheduled for February 27-28, 1975, both Hiquiana and Sakay separately registered members, creating two conflicting lists. To resolve this, COMELEC issued a resolution on February 5, 1975, recognizing for registration purposes the barangay captain officially recognized by the Department of Local Government and Community Development, which was Sakay.
ISSUE
Whether the petition for certiorari, prohibition, and/or mandamus seeking to annul the COMELEC resolution of February 5, 1975, has been rendered moot and academic.
RULING
Yes, the petition is moot and academic. The Supreme Court dismissed the petition on this ground. The legal logic is anchored on the principle 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 COMELEC resolution in question was specifically issued to address the administrative problem of identifying the proper official to oversee the registration of barangay members for the national referendum of February 27-28, 1975.
Since that referendum had already been held, concluded, and its results canvassed and announced by the time the Court deliberated on the petition, the resolution sought to be annulled had served its purpose and was no longer operative. Any ruling on its validity would have no practical legal effect, as the act it pertained to—the registration for that specific referendum—was already a consummated event. The Court emphasized that its dismissal was without prejudice to the continuation of the underlying quo warranto case (Civil Case No. Q-18398) and the related contempt proceedings pending before the Quezon City CFI, which would adjudicate the substantive rights to the office itself.