Case Digest (G.R. No. 194336)
Facts:
These consolidated certiorari petitions by Habib Ali, et al. (G.R. Nos. 69773-75), Mahadi M. Pimping (G.R. Nos. 69765-67), and Rashid Sampaco (G.R. No. 69846) assailed a COMELEC decision promulgated on November 19, 1985; the Court dismissed the petitions for lack of merit. The petitioners then filed motions for reconsideration—December 13, 1985 (jointly for Pimping and Ali, et al.) and December 20, 1985 (Sampaco)—and the Court required comment after the change of administration in accordance with Section 18, Rule 3, Rules of Court.
After the new Solicitor General and the COMELEC confirmed that the contested positions in Marawi City had been filled by officers-in-charge, the Court found that no modification or reversal of the November 19, 1985 decision was warranted and that the motions had become moot and academic. The Court thus denied the motions for reconsideration, with Chief Justice Teehankee maintaining a dissent rooted in alleged COMELEC legal errors, due process violations, and the absence of ballot revision and recount.
Issues:
- Whether the petitioners’ motions for reconsideration should be granted despite their alleged pro forma character.
- Whether the motions for reconsideration had become moot and academic due to subsequent appointments and the change of administration.
Ruling:
The Court denied the motions for reconsideration filed by the petitioners for lack of merit and further ruled that the motions had been rendered moot and academic by subsequent developments.
Ratio:
The Court found no showing in the new Solicitor General’s submissions and the COMELEC manifestation that required a modification or reversal of the November 19, 1985 decision. It also considered the post-decision circumstances, including the change in administration and the appointment of officers-in-charge for the contested local elective positions, as making the pending reconsideration matters non-justiciable in practical effect.
Doctrine:
- When supervening events make a case or incident no longer capable of effective relief, the pending matter becomes moot and academic.
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