Title
Anchorage Wood Industries, Inc. vs. Bislig Bay Lumber Co., Inc.
Case
G.R. No. L-30615
Decision Date
Jan 31, 1983
Timber concession boundary dispute between Bislig and Anchorage, involving multiple court rulings, rendered moot by dismissal of initial case.
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Case Digest (G.R. No. L-30615)

Facts:

    Background of the Dispute

    • The controversy arose from a dispute over the correct boundary line of the timber concessions in Agusan between Bislig Bay Lumber Co., Inc. (later known as Paper Industries Corporation of the Philippines) and Anchorage Wood Industries, Inc.
    • The dispute centered on two boundary lines: the Bernardo Line and the Genio Line.
    • The case involved multiple petitions and proceedings filed in different courts and at various stages by the parties.

    Chronology of Proceedings

    • December 16, 1968 – Bislig Bay Lumber Co., Inc. initiated an action in the Court of First Instance of Manila (Civil Case No. 75120) seeking to enjoin the implementation of an order by the Director of Forestry dated November 19, 1968. This order had declared the Bernardo Line as the boundary of the concessions.
    • May 21, 1969 – Judge Jesus P. Morfe of the Court of First Instance issued an injunction preventing Anchorage Wood Industries, Inc. and Eastcoast Development Enterprises from logging in the disputed area.
    • June 19, 1969 – Anchorage Wood Industries, Inc., along with Eastcoast Development Enterprises (the latter later withdrawing), assailed the injunction by filing a petition for certiorari and prohibition (G.R. No. L-30615) in the Supreme Court.
    • July 4, 1969 – The Secretary of Agriculture rendered a decision settling the boundary controversy by declaring the Genio Line as the correct boundary.
    • May 5, 1970 – The Office of the President of the Philippines affirmed the Secretary’s decision regarding the boundary line.
    • February 12, 1971 – Anchorage Wood Industries, Inc. filed a petition for certiorari and prohibition (Civil Case No. 14393) in the Court of First Instance of Rizal, Pasig Branch VI, seeking the annulment of the Presidential decision and maintaining that the Bernardo Line was correct.
    • April 5, 1971 – Judge Guardson M. Lood denied Bislig’s motion to dismiss the petition filed by Anchorage in Civil Case No. 14393.
    • October 14, 1971 – The Court of Appeals affirmed the denial of the motion to dismiss, thereby allowing the proceedings in Civil Case No. 14393 to continue.
    • February 14, 1974 – The case in G.R. No. L-30615 was consolidated with the proceedings from Civil Case No. 14393.
    • February 2, 1976 – The Court of First Instance of Manila dismissed Civil Case No. 75120 at Bislig’s instance and without objection from Anchorage or the Director of Forestry, ruling that the case had become moot and academic.
    • February 4, 1976 – In a related development, Anchorage filed a motion to dismiss its petition in G.R. No. L-30615 on the grounds that the originating Civil Case No. 75120 had been dismissed.
    • October 18, 1982 – Bislig was invited to comment on the motion to dismiss, but its counsel, despite receiving the resolution on October 27, 1982, failed to provide any response.
    • The lack of response from Bislig was noted as a factor contributing to the dismissal of the cases.

    Outcome of the Proceedings

    • Eventually, both cases (G.R. Nos. L-30615 and L-34475) were dismissed and declared terminated because they had become moot and academic.
    • No costs were imposed on the parties as a result of the dismissal.

Issue:

    Mootness and Academic Nature of the Case

    • Whether the dismissal of the antecedent Civil Case No. 75120, and subsequent inaction by Bislig, rendered the petitions moot and academic.
    • Determining if the failure of Bislig to comment on the motion to dismiss, despite being duly informed, affected the status of the pending petitions.

    Proper Judicial Discretion in Consolidated Cases

    • Whether the consolidation of the two petitions (G.R. No. L-30615 and L-34475) was appropriate in light of the evolving controversy over the boundary lines.
    • The extent to which judicial discretion allows dismissal of cases that have effectively lost their practical effect due to mootness.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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