Title
Pagdanga vs. Court of Appeals
Case
G.R. No. 202678
Decision Date
Sep 5, 2018
Petitioners sought mandamus to compel the Court of Appeals to resolve a petition amid allegations of delay, but the Supreme Court dismissed it as moot after the Court of Appeals rendered its decision.

Case Summary (G.R. No. 202678)

Factual Background

The dispute arose from competing claims to shares formerly owned by the late Antonio P. Madrigal. On November 23, 2007, Solid Guaranty, Inc. filed a complaint for interpleader through Pagdanganan, a minority shareholder, before the Regional Trial Court of Manila to resolve conflicting claims by the Madrigals and Citibank N.A. Hongkong over those shares. A Special Stockholders’ Meeting was held on November 26, 2007 at which new directors were elected. Solid Guaranty and Pagdanganan thereafter amended their interpleader complaint to implead the newly elected directors and to seek annulment of the meeting and the elections.

Proceedings in the Regional Trial Court

The Regional Trial Court entertained several interlocutory motions related to corporate records and stock transfers. On June 27, 2008, the trial court issued a Joint Order authorizing a stockholders’ meeting to avert prejudice to the corporation’s operations and to address matters in the agendas presented by opposing parties. The Special Annual Stockholders’ Meeting occurred on June 30, 2008, and new directors were elected. Solid Guaranty and Pagdanganan moved to prohibit the meeting, but the trial court permitted it in light of corporate exigencies, prompting petitioners to elevate the matter to the Court of Appeals.

Petition before the Court of Appeals

On July 11, 2008, Solid Guaranty, Pagdanganan, Alfonso, and Citibank filed a Petition for Certiorari, Prohibition, and Mandamus with a prayer for preliminary relief in the Court of Appeals, alleging grave abuse of discretion by the Regional Trial Court in allowing the June 30, 2008 meeting. The petition impleaded the Madrigals, the newly elected officers and directors, and the presiding trial court judge. The Court of Appeals required comments and directed memoranda; the parties filed pleadings and replies through October 2008.

Supplemental Petitions and Motions in the Court of Appeals

Petitioners filed successive motions for leave to file supplemental petitions, including a Second Supplemental Petition received October 6, 2008, and a Motion for Leave to File Third Supplemental Petition filed December 12, 2008. The Court of Appeals recognized that the case could have been submitted earlier but deferred decision to afford due process because of the supplemental pleadings. The Court of Appeals subsequently expunged the Second and Third Supplemental Petitions in its October 6, 2010 Resolution and deemed the case submitted for decision. Petitioners moved for reconsideration of that resolution on October 29, 2010.

Subsequent Filings, Substitution, and Motions

Petitioner Pagdanganan died on March 24, 2011 and was substituted by his heirs. The Court of Appeals directed comments on the motion for reconsideration, which prompted further oppositions and pleadings. Petitioners filed a Motion for Mediation on January 2, 2012 and a Motion for Resolution on March 1, 2012. The multiplicity of pleadings continued while the matter remained pending at the Court of Appeals.

Filing of Petition for Mandamus with the Supreme Court

On August 2, 2012, the heirs of Pagdanganan, Alfonso, and Citibank filed a petition for mandamus in the Supreme Court praying that the Court compel the Court of Appeals to resolve CA-G.R. SP No. 104291, alleging inordinate delay and neglect of duty by the Court of Appeals in violation of their constitutional right to speedy disposition of cases. Respondents opposed and attributed any delay to petitioners’ own supplemental petitions and motions.

Court of Appeals Resolution and Decision During Pendency of the Mandamus Petition

While the mandamus petition was pending before the Supreme Court, the Court of Appeals issued a Resolution dated December 14, 2012 denying the Motion for Mediation and the Motion for Reconsideration and reiterating that the case was submitted for decision. The Court of Appeals thereafter rendered a Decision on February 8, 2013 dismissing the petition on the merits for lack of grave abuse of discretion by the trial court. The Court of Appeals resolved the motion for reconsideration by Resolution dated March 10, 2014, thereby completing final action on CA-G.R. SP No. 104291.

Parties’ Contentions before the Supreme Court

Petitioners urged this Court to issue a writ of mandamus compelling the Court of Appeals to decide their 2008 petition, asserting that the Court of Appeals violated the time limits of CONST., art. VIII, sec. 15(1) and their right under CONST., art. III, sec. 16 by resolving the matter only in 2013. Respondents countered that the delay, if any, was attributable to petitioners’ own repetitive supplemental petitions and motions, and that the mandamus petition had become moot because the Court of Appeals had already issued its February 8, 2013 Decision.

Issue Presented

The dispositive issue was whether the Court of Appeals committed inordinate delay in resolving CA-G.R. SP No. 104291 so as to warrant issuance of a writ of mandamus compelling it to decide the case at an earlier time.

Ruling of the Supreme Court

The Supreme Court dismissed the petition for mandamus as moot and academic. The Court found that the Court of Appeals had rendered a Decision on February 8, 2013 and had resolved the motion for reconsideration on March 10, 2014, therefore disposing of CA-G.R. SP No. 104291 with finality during the pendency of the mandamus petition. The Court noted controlling authorities establishing mootness doctrine, including Baldo v. Commission on Elections, and earlier precedents where mandamus petitions were dismissed when the relief sought had been overtaken by subsequent events.

Legal Basis and Reasoning

The Court first applied the doctrine that a petition becomes moot when no actual controversy remains or when no practical relief can be given. It relied on Baldo v. Commission on Elections and other authorities to conclude that issuance of a writ of mandamus would be futile once the Court of Appeals had finally resolved the underlying petition. The Court then addressed the case on the merits hypothetically. It reiterated the constitutional guarantee of speedy disposition and the specific time frames of CONST., art. VIII, sec. 15(1), which affords the Court of Appeals twelve months to resolve cases after submis

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