GR L 69773; (August, 1986) (Digest)
G.R. Nos. L-69773-75, L-69765-67, L-69846 August 28, 1986
Habib Ali, et al., Mahadi M. Pimping, and Rashid Sampaco, petitioners, vs. The Commission on Elections, et al., respondents.
FACTS
The petitioners were candidates for local offices in Marawi City who filed election protests. In a consolidated decision dated November 19, 1985, the Supreme Court dismissed their petitions for certiorari, which challenged COMELEC resolutions that had decided the election contests without conducting a physical revision and recount of the ballots. The petitioners filed motions for reconsideration. Following the change in national administration in February 1986, the Court directed the new Solicitor General to comment on these motions. The Solicitor General manifested that the COMELEC maintained the validity of its original decision but noted that officers-in-charge had since been appointed to the contested positions of Mayor and Vice-Mayor of Marawi City. The petitioners argued the cases were not moot because the validity of the elections bore on their right to claim damages.
ISSUE
Whether the motions for reconsideration of the Court’s November 19, 1985 decision should be granted.
RULING
The Court denied the motions for reconsideration. The legal logic proceeds from the doctrine of mootness. A case becomes moot when it ceases to present a justiciable controversy because the issues have been resolved or have lost their practical significance. Here, the core objective of the petitions—to contest the right to hold the local elective offices—was rendered academic by the supervening appointment of officers-in-charge to those very positions by the new administration. This change in the factual landscape removed any actual substantial relief the Court could grant regarding the occupancy of the offices. The Court found no compelling reason to reverse its prior decision, especially as the new Solicitor General’s manifestation did not advocate for modification. While the dissenting opinion, referencing the original decision, argued that the COMELEC committed grave errors by deciding without a ballot recount and violated due process, the majority held that these substantive arguments were overtaken by the mootness of the case. The denial was thus based on both a reaffirmation of the original decision’s merits and the supervening mootness of the electoral contest.