Title
Bangued Water District vs. Herdo
Case
G.R. No. 54043
Decision Date
Nov 28, 1980
Petitioner sought certiorari to annul proceedings; parties entered a Compromise Settlement approved by the court, rendering the petition moot. SC upheld the settlement's validity and dismissed the case.
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Case Digest (G.R. No. 54043)

Facts:

    Background of the Case

    • The Bangued Water District, represented by Edgar B. H. Hojilla in his capacity as Acting Chairman of the Board of Directors, filed a petition for certiorari.
    • The petition sought relief against Hon. Harold M. Hernando, Presiding Judge, Branch I of the Court of First Instance of the Province of Abra, as well as against Dr. Ben Bringas and other private respondents.

    Relief Sought and Petition Details

    • The petitioner requested a writ of certiorari to have the proceedings in the lower court certified for review.
    • A preliminary injunction was also sought to protect the rights of the petitioner pending the proceedings.
    • After due hearing, the petitioner prayed that judgment be rendered annulling or modifying the respondent judge’s proceedings in accordance with the law.

    Emergence of a Compromise Settlement

    • Subsequent to the filing of the petition, both parties in Civil Case No. 1257 entered into a "Compromise Settlement."
    • Key points in the settlement included:
    • The respondents’ undertaking to improve the Bangued Water System at a cost of P3,310,000.00 with immediate effect upon signing.
    • An agreement to perform a thorough accounting of all funds and materials of the Bangued Water District.
    • The petitioners’ waiver of any claims for damages and accounting of funds/materials as a benefit derived from the promised improvements.
    • The settlement also detailed the maintenance of existing water rates (P5.00 for domestic users and P10.00 for commercial/industrial users) until the water system was improved.
    • A structured schedule for revised water rates was provided:
    • For domestic, school, and hospital users, a tiered rate system based on cubic meter consumption beyond specified thresholds.
    • For commercial, industrial, and bulk users, the rates were to be doubled or tripled respectively according to the rate for domestic users.
    • Additional stipulations included:
    • Any future change in water rates was to be determined by the parties in accordance with existing laws and regulations.
    • The binding commitment of the Bangued Water Consumers to support the agreed rates, ensuring operation, maintenance, repayment of the loan, and other expenses.

    Judicial Action on the Settlement

    • The respondent judge rendered a final judgment approving the compromise agreement.
    • The judge ordered that the parties comply with the terms and conditions of the settlement.
    • Consequently, on the basis of the settlement, the petition for certiorari was dismissed with the final order stating: "WHEREFORE, as prayed for, this case is hereby DISMISSED."

Issue:

    Jurisdiction and Appropriateness of Review

    • Whether the petition for certiorari was the proper remedy given that the dispute had effectively been resolved by a compromise.
    • The appropriateness of issuing a writ of certiorari to review the proceedings of a judge who had already rendered final judgment on a compromise settlement.

    Effect of the Compromise Settlement on the Petition

    • Whether the settlement, which included waivers of claims and a commitment to maintain certain water rates, extinguished or affected the standing of the petition.
    • The impact of the approved compromise on the petitioners’ rights and the subsequent dismissal of their petition.

    Judicial Oversight

    • Whether the lower court's final judgment approving the compromise settlement was proper and beyond the scope of review by certiorari.
    • The extent to which judicial review should interfere in cases where parties voluntarily agree to a settlement that ends their disputes.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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