G.R. No. 225301 - Department of Trade and Industry vs. Enriquez

A news article alleged corrupt practices in issuance of importation clearances by a DTI officer.
Secretary Adrian Cristobal instructed Undersecretary Dimagiba (Usec. Dimagiba) to investigate.

On April 14, 2016, Usec. Dimagiba issued a memorandum reporting unauthorized import clearances issued by Danilo B. Enriquez (Enriquez), Fair Trade and Enforcement Bureau (FTEB) Director.
On April 22, 2016, Sec. Cristobal issued D.O. No. 16-34 creating the SIC with authority to investigate Enriquez and to impose preventive suspension.

Between May 2 and 12, 2016, Enriquez issued memoranda to Usec. Dimagiba, Sec. Cristobal, and SIC members questioning their authority, citing lack of due process, and arguing only the Ombudsman or PAGC/PACC had jurisdiction over presidential appointees.
On May 12, 2016, SIC issued a Show Cause Memorandum.
On May 19, 2016, SIC found prima facie case, filed Formal Charge for gross insubordination, misconduct, abuse of authority, and conduct prejudicial; attached evidence and imposed 90-day preventive suspension effective immediately.

Enriquez filed a Petition for Certiorari, Prohibition, and Mandamus with Prayer for TRO and Injunction before RTC Branch 77, arguing lack of disciplinary jurisdiction by DTI Secretary/SIC.
Petitioners (DTI) argued RTC lacked jurisdiction, that SIC had authority under the Administrative Code to investigate and suspend, and due process was observed.
On June 27, 2016, RTC granted petition in part: nullified the Formal Charge and preventive suspension, prohibited SIC from proceeding, and ordered restoration of Enriquez to his post.

DTI issued D.O. No. 16-63 on July 4, 2016, appointing an OIC for FTEB, implying Enriquez’s term had expired.
Petitioners filed a Petition for Review on Certiorari under Rule 45 seeking reversal of RTC decision. Enriquez contended the petition was moot; petitioners countered administrative proceedings survive separation from service.

Whether the DTI Secretary has disciplinary jurisdiction to investigate and suspend a bureau director who is a presidential appointee.
Whether the RTC erred in entertaining a petition for certiorari, prohibition, and mandamus against DTI Secretary and SIC.
Whether Enriquez’s separation from service renders the petition moot and academic.