Title
Ozaeta vs. Oil Industry Commission
Case
G.R. No. L-34574-79
Decision Date
Jun 30, 1980
Petitioners challenged Oil Industry Commission's authority to grant provisional petroleum price increases; Supreme Court dismissed case as moot after OIC decided main applications.
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Case Digest (G.R. No. L-34574-79)

Facts:

  1. Background of the Case:
    The case involves a petition for prohibition with preliminary injunction filed by Emiliano O. Ozaeta and Remigio Castillo against the Oil Industry Commission (OIC) and several oil companies, including Esso Philippines, Inc., Mobil Oil Philippines, Inc., Caltex Philippines, Inc., Getty Oil (Philippines), Inc., Shell Philippines, Inc., Filoil Refinery Corporation, and Filoil Marketing Corporation. The petitioners sought to restrain the OIC from hearing and deciding the oil companies' motions for provisional relief, which requested temporary increases in the prices of petroleum products.

  2. Applications for Price Increases:
    From November 12 to November 18, 1971, the respondent oil companies filed separate applications with the OIC (docketed as OIC Cases Nos. 01-06) for the setting of maximum selling prices of gasoline and other petroleum products. They also filed motions for provisional relief, seeking interim price increases pending the final determination of their applications.

  3. Opposition by Petitioners:
    On December 1, 1971, the petitioners filed an opposition to the applications for price increases and the motions for provisional relief. They argued that:

    • The OIC lacked authority to grant provisional price increases.
    • Section 2, Rule 13 of the OIC's Rules of Practice and Procedure did not apply to the motions.
    • The motions lacked merit.
  4. OIC's Response:
    On December 20, 1971, the OIC denied the petitioners' opposition and asserted its jurisdiction to hear the motions for provisional relief. The OIC stated that such motions sought interim remedies and could be granted ex parte, but it opted to conduct a hearing with notice to all parties.

  5. Motion for Reconsideration:
    On December 28, 1971, the petitioners filed a motion for reconsideration, arguing that the OIC Act did not authorize provisional price increases. The OIC denied the motion on January 7, 1972, citing its powers under Section 8(f) of Republic Act No. 6173.

  6. Petition to the Supreme Court:
    On January 14, 1972, the petitioners filed a petition with the Supreme Court, seeking to annul the OIC's orders and restrain it from hearing the motions for provisional relief. The Court issued a restraining order on January 21, 1972, enjoining the OIC from acting on the motions but allowing it to proceed with the main applications for price increases.

  7. OIC's Decision on the Merits:
    On September 18, 1972, the OIC rendered a decision on the main applications, granting an across-the-board increase of not more than two centavos per liter in the wholesale prices of locally refined petroleum products.

  8. Mootness of the Case:
    The respondents argued that the petition had become moot and academic since the OIC had already decided on the main applications and had no intention of acting on the motions for provisional relief.

Issue:

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Ruling:

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Ratio:

  1. Mootness Doctrine:
    The Court reiterated its consistent holding that it only decides actual controversies and not hypothetical cases. Since the OIC had already rendered a decision on the main applications, the issue of provisional relief was no longer relevant.

  2. OIC's Authority:
    While the Court did not rule on the merits of the OIC's authority to grant provisional relief, it noted that the OIC had decided not to act on the motions for provisional relief and instead focused on the main applications. This rendered the issue of provisional relief moot.

  3. Judicial Restraint:
    The Court emphasized that it would not rule on issues that no longer required resolution, especially when the parties themselves appeared to recognize the mootness of the case.


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