G.R. No. L-55798 July 20, 1985
CORAZON S. SAYCO, ET AL., petitioners, vs. PHILIPPINE SUGAR COMMISSION AND NATIONAL SUGAR TRADING CORPORATION, respondents.

FACTS

Petitioners, sugar planters, filed a special civil action for prohibition against the Philippine Sugar Commission (PHILSUCOM) and its trading arm, the National Sugar Trading Corporation (NASUTRA). They did not challenge the constitutionality of Presidential Decree No. 388, which created PHILSUCOM as the single buying and selling agency for sugar with price-setting powers. Instead, they contended that the law’s application was unconstitutional, alleging that PHILSUCOM’s directive for sugar mills to issue warehouse receipts (quedans) in its name for all sugar, including the planters’ share, constituted an oppressive deprivation of property without due process. They argued this act was ultra vires, as the decree did not authorize such a transfer of ownership.
In its Resolution dated December 3, 1982, the Court dismissed the petition. It found the sugar industry imbued with public interest, making it a proper subject of police power measures. The Court noted that PHILSUCOM’s protective pricing policy, explained by the Solicitor General, aimed to shield planters from drastic market falls and ensure returns above production cost. It held there was no showing of arbitrary or oppressive application of the law. Petitioners subsequently filed a motion for reconsideration.

ISSUE

Whether the petition for prohibition has been rendered moot and academic.

RULING

Yes, the petition is dismissed for being moot and academic. The legal logic is grounded in the doctrine of mootness, which dictates that courts will not adjudicate cases where there is no longer an actual, live controversy between the parties. A supervening event, the issuance of Presidential Decree No. 1791 on February 21, 1985, fundamentally altered the legal landscape that gave rise to the dispute. Section 6 of this new decree mandated the conversion of the respondent NASUTRA into a private corporation, the Philippine Sugar Marketing Corporation (PHILSUMA), to be wholly owned by sugar producers by December 31, 1985.
This legislative act effectively dissolved the core structure against which the petitioners’ complaint was directed. The suit was aimed at the acts of the government-owned PHILSUCOM and its subsidiary NASUTRA. With the statutory directive to privatize and transfer ownership to the planters and millers themselves, the very entities being challenged were slated to cease existing in their current form. Consequently, any judicial declaration on the alleged ultra vires or unconstitutional acts of these soon-to-be-defunct agencies would have no practical legal effect. The Court, following its precedent in the related case of Ledesma v. Philippine Sugar Commission, therefore denied the motion for reconsideration and dismissed the petition, as resolving it would be an exercise in futility with no tangible impact on the rights of the parties.