G.R. No. L-75089. November 26, 1986.
LILIA LOPEZ-JISON, petitioner, vs. THE SOCIAL SECURITY COMMISSION AND FELIPE DIACAMOS, respondents.

FACTS

Private respondent Felipe Diacamos filed a complaint with the Social Security Commission against petitioner Lilia Lopez-Jison, owner-operator of Hacienda Doña Lilia. He sought payment for unpaid SSS premium contributions, corresponding penalties, and damages equivalent to the retirement benefits he would have received had he been properly reported for coverage during his employment from June 18, 1960, to December 5, 1979. The Commission ruled in favor of Diacamos, ordering the SSS to compute and bill Jison for the liabilities, including contributions and a 3% monthly penalty for late payment.
After the Commission’s decision became final, the SSS computed Jison’s total liability at P11,416.98, comprising contributions and accumulated penalties. To prevent an auction of her levied properties, Jison paid the full amount on May 29, 1985. Subsequently, the SSS demanded an additional P373.72, representing the balance of penalties accruing from the due date of the contributions to the date of her late payment. Jison protested this further demand, arguing her obligation under the judgment had been fully satisfied, and filed the present Petition for Prohibition to permanently restrain the Commission from enforcing the judgment and writ of execution.

ISSUE

Whether the Petition for Prohibition is rendered moot and academic due to subsequent developments extinguishing the petitioner’s remaining obligation.

RULING

Yes, the petition is moot and academic. The core legal principle applied is that a court will not adjudicate a case when a supervening event has eliminated the actual controversy between the parties. Here, the respondent Social Security Commission, in lieu of filing a Comment, submitted a Manifestation citing Executive Order No. 28 issued on July 16, 1986. This Executive Order provided for the condonation of the 3% penalty imposed on delinquent employers. Consequently, the SSS declared it was no longer pursuing its claim against Jison. Attached documentation, specifically the Statements of Premiums and Penalties Receivable for the case, showed a zero balance, confirming the extinction of her liability.
The legal logic is straightforward: prohibition is a preventive remedy to restrain a tribunal from proceeding without or in excess of jurisdiction or with grave abuse of discretion. However, its grant requires a clear right to the relief sought and the existence of an ongoing act to be prohibited. The condonation under Executive Order No. 28 and the SSS’s confirmation of a zero balance constituted a supervening event that resolved the dispute. With no remaining obligation to collect and no further enforcement action threatened, the factual and legal basis for the petition ceased to exist. The Court, therefore, had no live controversy to resolve and dismissed the petition on mootness grounds.