GR L 58807; (December, 1983) (Digest)
G.R. No. L-58807-08 December 21, 1983
TEODORO F. VALENCIA, petitioner, vs. EMMANUEL M. PELAEZ and HONORABLE NOLI CATLI, in his capacity as CITY FISCAL of CAGAYAN DE ORO CITY, respondents.
FACTS
Petitioner Teodoro F. Valencia sought to restrain the City Fiscal of Cagayan de Oro City from conducting a preliminary investigation in I.S. Nos. 410264 and 410265, which were libel complaints filed by private respondent Emmanuel M. Pelaez. The libel cases stemmed from statements made by Valencia in the Daily Express. The Supreme Court initially issued a temporary restraining order. During the pendency of the petition, both parties, out of respect for the Court, mutually agreed not to make any public comments regarding the case’s merits, rendering a related motion to enjoin such comments moot.
Subsequently, on August 24, 1983, private respondent Pelaez filed a Motion to Withdraw the charges with the City Fiscal. In his motion, Pelaez cited a profound spiritual renewal following a violent attack on his life in July 1982. He expressed a commitment to Christian reconciliation and love, stating he had forgiven those involved and felt pursuing the complaints would contradict these principles. He therefore decided to desist and invited all parties to consider the matter closed.
ISSUE
Whether the petition for certiorari and prohibition has been rendered moot and academic by the private complainant’s withdrawal of the libel charges.
RULING
Yes, the petition is dismissed for being moot and academic. The Court agreed with private respondent Pelaez’s manifestation that his act of filing a Motion to Withdraw the charges had rendered the principal petition moot. The core objective of Valencia’s petition was to stop the preliminary investigation. That objective was effectively achieved by the complainant’s own voluntary act of seeking to terminate the proceedings. The Court noted the petitioner’s comment expressing his desire to have had the chance to prove his innocence and uphold freedom of speech and the press. However, the legal reality is that the supervening event—the withdrawal of the complaint by the sole private complainant—removed any actual and justiciable controversy. There was no longer an active investigation to restrain. Consequently, the Court could not rule on the hypothetical merits of the libel case or the alleged constitutional violations, as there was no live case or dispute to adjudicate. The dismissal was without costs.