Title
Manila Jockey Club, Inc. vs. Montano, Jr.
Case
G.R. No. L-24465
Decision Date
Feb 28, 1977
Manila Jockey Club sought a permit for horse racing on Manila Foundation Day, denied by GAB. Lower court granted permit, but appeal dismissed as moot due to passed date and repealed law.

Case Digest (G.R. No. 103560)
Expanded Legal Reasoning Model

Facts:

  • Background of the Permit Application
    • On June 18, 1964, the Manila Jockey Club, Inc. (petitioner-appellee) filed an application with the Games and Amusements Board for a permit to hold or conduct horse racing at the San Lazaro Hippodrome.
    • The proposed race date, June 24, 1964, was declared a Special Public Holiday in Manila in observance of Manila Foundation Day as per Presidential Proclamation No. 257 dated June 8, 1964.
  • Action of the Games and Amusements Board and the Executive
    • The board, consisting of respondent Justiniano N. Montano (Chairman) and members Alfredo Lozano and Jose Roxas, refused to issue the license based on a letter from the then Acting Executive Secretary, Calixto O. Zaidivar.
    • The letter stated that under Section 4 of Republic Act No. 309 (as amended by Republic Act No. 983), horse races may occur only on legal holidays prescribed nationwide—excluding Holy Thursday, Holy Friday, July 4th, and December 30th—and not on a special public holiday applicable only to a specific locale.
  • Petition for Certiorari and Preliminary Mandatory Injunction
    • On June 23, 1964, dissatisfied with the board’s decision, the petitioner-appellee filed a petition for certiorari with a preliminary mandatory injunction in the Court of First Instance of Manila.
    • The petition argued that the petitioner was lawfully entitled to the permit on the basis that the declared special public holiday (Manila Foundation Day) should be treated as a legal holiday under the relevant statute.
    • The petitioner sought issuance of a writ compelling the Games and Amusements Board to authorize the permit and to refrain from averting the conduct of the horse race scheduled for June 24, 1964.
  • Procedural Developments
    • The lower court issued the writ of preliminary mandatory injunction on the same day, June 23, 1964, upon approval of a P5,000.00 bond.
    • The respondents submitted their answers in mid-July 1964, and the case proceeded to pre-trial on November 7, 1964, where the parties agreed to resolve the dispute based upon their pleadings and memoranda.
    • The Court of First Instance rendered its decision on February 17, 1965, which the respondents-appellants subsequently contested on direct appeal by the Solicitor General.
  • Contention on the Scope of Legal Holidays
    • The respondents-appellants argued that “Manila Foundation Day,” being a Special Public Holiday limited to the City of Manila, did not fall within the category of legal holidays under Section 4 of Republic Act No. 309, as amended.
    • They contended that this misapplication of the law led to an abuse of discretion in denying the proper permit and license for conducting the horse race.
  • Mootness Due to Change in Statutory Framework
    • By the time of the appeal, the event (the horse race scheduled for June 24, 1964) had long passed.
    • Additionally, Republic Act No. 309, which formed the basis of the suit, had been repealed by Presidential Decree No. 420, promulgated on March 20, 1974, thereby abolishing the Games and Amusements Board and vesting broader powers in the Philippine Racing Commission.
    • The change in the administrative and statutory landscape rendered the issue presented in the petition moot and academic.

Issues:

  • Whether the Manila Jockey Club was entitled to a permit to conduct horse racing on June 24, 1964, on the grounds that the day was a Special Public Holiday (Manila Foundation Day) under the applicable provisions.
    • Did Republic Act No. 309 (as amended) allow for horse racing on a local or special public holiday, or strictly on legal holidays prescribed nationwide?
    • Whether the directive from the Acting Executive Secretary, as communicated to the Games and Amusements Board, was a correct interpretation of the law.
  • The appropriateness of a petition for certiorari with a preliminary mandatory injunction in compelling the issuance of the permit for an event whose scheduled date had already passed.
    • Given that the event date was in the past, was the relief sought still justiciable?
    • Whether the legal and factual issues had become moot in light of subsequent changes in the law (the repeal of Republic Act No. 309 by PD No. 420).
  • Whether the decision of the lower court, which granted the preliminary mandatory injunction, reflected or constituted a grave abuse of discretion in interpreting the statutory framework governing racing permits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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