Case Summary (G.R. No. 220514)
Antecedents and Allegations
The petitioners contested the election results, asserting that the elected respondents lacked the necessary qualifications as mandated by the association’s By-Laws. Specific accusations included the failure of the elected respondents to possess a Motorized Tricycle Operation Permit (MTOP) and the lack of verification of educational qualifications, particularly high school graduation. Additionally, the petitioners claimed that the election process was flawed due to the imposition of restrictive voting eligibility requirements, thereby disenfranchising some members. They further alleged that there was no registration of voters conducted before the election and that the election Committee was improperly constituted.
Initial Proceedings and RTC Ruling
Following the election, the petitioners filed a protest with the Committee on Elections on February 1, 2010. When the committee failed to act, the petitioners escalated the matter to the Regional Trial Court (RTC) in Parañaque City. In its ruling, dated February 10, 2014, the RTC dismissed the case, declaring it moot and academic, as the respondents' terms had expired on January 31, 2013.
Court of Appeals Ruling
The petitioners appealed the RTC's decision to the Court of Appeals (CA), which rendered its decision on April 30, 2015, affirming the RTC's ruling. The CA concluded that the case did not meet the criteria for an action capable of repetition yet evading review, primarily because the petitioners did not participate in the subsequent election held in 2012, while the respondents did reelection.
Justiciable Controversy and Court's Ruling
At the heart of the petitioners’ arguments was whether a justiciable controversy remained after the expiration of the respondents' terms. The court reiterated that an actual case or controversy is necessary for judicial adjudication. It distinguished between moot and academic cases and emphasized that where supervening events result in the resolution of the contentious issue, courts typically decline jurisdiction. In this instance, the expiration of the respondents' terms was a supervening event that rendered the case moot.
The petitioners argued the case fell under the “capable of repetition, yet evading review” exception. The court evaluated two factors: whether the contested action was too short for complete litigation and whether there was a reasonable expectation of the same action recurring. However
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Antecedents of the Case
- The petitioners are members of the Samahang Barangay Don Bosco Tricycle Operators and Drivers, Inc. (SBDBTODI), a non-stock, non-profit association registered with the Securities and Exchange Commission (SEC).
- They contested an election that took place on January 30, 2010, against the respondents, who were the successful candidates in that election.
- The petitioners alleged that the respondents lacked the necessary qualifications as stipulated in the association's By-Laws, particularly the lack of a Motorized Tricycle Operation Permit (MTOP) and educational qualifications.
- The petitioners claimed that the election process was tainted, as the respondents imposed unfair voting requirements, which disenfranchised members who would have supported the petitioners.
- They also argued that there was no proper registration of voters prior to the election and that the Committee on Elections was improperly constituted due to familial ties with the candidates.
RTC Ruling
- The Regional Trial Court (RTC) rendered a decision on February 10, 2014, dismissing the case on th