G.R. No. L-68649 December 29, 1986
Robinson Lomo, petitioner, vs. Hon. Garison G. Mabelin, et al., respondents.

FACTS

The case originated from an election for a director position in the Misamis Occidental II Cooperative, Inc. (MOELCI II). Petitioner Robinson Lomo filed his certificate of candidacy five days before the election, contrary to a cooperative rule requiring filing at least fifteen days prior. His candidacy was thus disqualified by the Nomination Committee. However, on election day, a general assembly of members nominated Lomo via a petition signed by 22 members, as allowed by the cooperative’s by-laws. In the ensuing election, Lomo received more votes than the sole official candidate, J. Antonio Lim. The Election Committees, however, declared all votes for Lomo as stray, proclaimed Lim the winner, and the Board of Directors confirmed Lim’s election.
Lomo filed a petition with the Regional Trial Court, seeking a writ of preliminary injunction to stop Lim from assuming office and to compel his own proclamation. The trial court denied the injunction, finding no irreparable injury to Lomo. Lim subsequently took his oath. Lomo then elevated the matter to the Supreme Court via a special civil action.

ISSUE

Whether the Supreme Court should grant the petition to annul the trial court’s order and compel Lomo’s proclamation as the duly elected director of MOELCI II.

RULING

The Supreme Court dismissed the petition for being moot and academic. The legal logic is grounded on the principle that courts will not adjudicate cases where no practical relief can be granted due to supervening events. During the pendency of the petition, Lomo was appointed and assumed the position of Vice-Mayor of Jimenez, Misamis Occidental, effective May 1, 1986. Section 3 of the MOELCI II By-Laws explicitly disqualifies any person holding an elective government office above the level of Barangay Captain from serving as a board member. By virtue of his assumption of the vice-mayoral office, Lomo became ineligible to remain or serve as a director of the cooperative.
Consequently, the very purpose of the petition—to have Lomo installed as director—was rendered impossible. Even if the Court were to rule on the merits of the election controversy, such a ruling would be an abstract proposition with no practical legal effect, as Lomo could no longer assume the contested position. The Court therefore refrained from expressing an opinion on the underlying issues regarding the validity of his nomination or the election committee’s actions, as the case had been overtaken by this dispositive supervening event.