G.R. No. 138381 - Government Service Insurance System vs. Commission on Audit

Petitioners are members of Samahang Barangay Don Bosco Tricycle Operators and Drivers, Inc. (SBDBTODI), a non-stock, non-profit association duly registered with the Securities and Exchange Commission (SEC).
The petitioners were candidates in an intra-corporate election held on January 30, 2010, while the respondents were the opposing candidates and, ultimately, the winners of that election.

The petitioners filed a complaint seeking the nullification of the January 30, 2010, election on several grounds:

The respondents, including Silverio Navarro (the elected President) and other elected members of the Board of Directors, allegedly failed to meet qualifications—specifically, not having secured a Motorized Tricycle Operation Permit (MTOP) as mandated by the Association’s By-Laws.
The elected officers (President, Vice-President, Secretary, Treasurer, and Auditor) were claimed not to have proven that they were high school graduates, a qualification required under the association’s constitution and by-laws.
The respondents purportedly imposed arbitrary requirements (i.e. barangay clearance, National Bureau of Investigation clearance, police clearance, and a valid driver’s license) that disenfranchised a number of members who would have voted for the petitioners.

There was no registration of voters conducted prior to the election as required by the association’s Constitution and By-Laws.
The Committee on Elections was illegally constituted because some of its members were relatives of the candidates.

On February 1, 2010, prior to the RTC filing, the petitioners filed a written protest before the Committee on Elections.
The failure of the Committee to act on this protest led the petitioners to initiate a complaint before the Regional Trial Court (RTC) adjudicating the dispute.

While the case was pending before the RTC, the Association held another election on December 15, 2012, to choose new officers and Board of Directors.
The RTC, in its February 10, 2014 Decision, dismissed the case for being moot and academic on the ground that the term of office of the respondents had already expired on January 31, 2013.

The respondents contested the petitioners’ evidence, particularly the master list of purported association members with MTOPs, alleging that it contained numerous erasures and insertions and lacked certification by the Association’s President.
They also maintained that the petitioners failed to specifically identify the eligible members allegedly disenfranchised from voting.

Whether the petition presents an actual case or controversy, given that the respondents’ term of office has expired, rendering the issues moot and academic.
Whether, despite the expiration of office, the case falls under the exception of a “capable of repetition yet evading review.”

The challenged action was too short in duration to be fully litigated before its cessation or expiration.
There is a reasonable expectation that the same complaining party would be subjected to the same legal action at a future time.

Whether the inherent issues regarding qualifications and election irregularities could reoccur in future instances or be remedied in subsequent elections.