Title
Balasabas vs. Vamenta, Jr.
Case
G.R. No. L-46459
Decision Date
Jan 31, 1979
Land dispute over sugarcane harvesting; respondents' Manifestation rendered petition moot, prompting dismissal and focus on main case merits.
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Case Digest (G.R. No. L-46459)

Facts:

  1. Parties Involved:

    • Petitioner: Walter Balasabas
    • Respondents: Hon. Cipriano Vamenta, Jr. (Presiding Judge, CFI of Negros Oriental), Genoveva Gonzales, Alicia Gonzales, Ignacio Gonzales, Elvira Gonzales, and Adelaida Gonzales (married to Arnulfo Umbac).
  2. Case Background:

    • The case arose from Civil Case No. 6469 for Specific Performance with Preliminary Mandatory Injunction filed by private respondents (Gonzales family) against petitioner Walter Balasabas.
    • The respondents sought to regain possession of a disputed land and prevent the petitioner from harvesting and milling sugarcane.
  3. Orders Challenged:

    • March 25, 1977 Order: Respondent Judge granted a Writ of Preliminary Mandatory Injunction, ordering petitioner to restore possession of the land to private respondents and maintain the status quo. The petitioner was also restrained from harvesting sugarcane and committing further acts of dispossession. A bond of P5,000 was required.
    • May 19, 1977 Order: The respondent Judge denied petitioner’s Motion for Reconsideration of the March 25, 1977 Order.
  4. Petition for Certiorari:

    • Petitioner filed a petition for certiorari on July 11, 1977, seeking to set aside the aforementioned orders, alleging grave abuse of discretion by the respondent Judge and the absence of an adequate remedy.
  5. Subsequent Developments:

    • On October 20, 1977, private respondents filed a Manifestation in the lower court stating that they had not taken physical possession of the land and had no intention to do so. They also expressed no objection to the petitioner taking possession of the land.
  6. Petitioner’s Insistence:

    • Despite the Manifestation, petitioner insisted on resolving the issues raised in the petition, fearing that private respondents might take an inconsistent stand in the future.

Issue:

  1. Whether the petition for certiorari should be dismissed as moot and academic due to the Manifestation filed by private respondents.
  2. Whether the respondent Judge acted with grave abuse of discretion in issuing the March 25, 1977 Order and denying the Motion for Reconsideration.

Ruling:

The Supreme Court dismissed the petition as moot and academic. The Court held that with the Manifestation filed by private respondents, the issues raised in the petition had become moot. The respondent Judge was directed to set aside the March 25, 1977 Order and the Writ of Preliminary Mandatory Injunction and proceed with the determination of the merits of the main case.

Ratio:

  1. Mootness of the Petition:

    • The Manifestation filed by private respondents rendered the petition moot and academic. Since they no longer intended to take possession of the land and had no objection to the petitioner’s possession, the controversy over the preliminary injunction ceased to exist.
  2. Judicial Economy:

    • The Court emphasized the principle of judicial economy, stating that it would not resolve issues that no longer present an actual controversy.
  3. Grave Abuse of Discretion:

    • The Court did not address the issue of grave abuse of discretion by the respondent Judge, as the petition had already been rendered moot by the Manifestation.
  4. Direction to the Lower Court:

    • The respondent Judge was directed to set aside the March 25, 1977 Order and the Writ of Preliminary Mandatory Injunction and focus on resolving the merits of the main case.


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