G.R. No. 157384 - Bildner vs. Ilusorio

Case Summary (G.R. No. 157384)

Key Dates and Documents

PSME 63rd National Convention and elections: October 21–25, 2015.
Letter-protest by Engr. Conti: October 26, 2015.
PSME-COMELEC Omnibus Resolution annulling certain NCR tally sheets and declaring Conti’s group winners: November 22, 2015.
PSME officers election (Conti declared president): November 25, 2015.
PRC acknowledgement/letter recognizing Conti: December 18, 2015 (followed by Office Order No. 2016-56 dated February 10, 2016).
Intra-corporate action filed before RTC Manila-Br. 24 by Conti’s group: November 26, 2015; RTC Br. 24 Decision: August 8, 2016 (declaring valid the Omnibus Resolution as to board membership but voiding the November 25, 2015 officers’ election).
Writ of execution: August 23, 2016.
PRC suspension of COGS/CPD requirement: PRC Resolution No. 107, August 5, 2016.
Petition for declaration of nullity of PRC Office Order No. 2016-56 filed before RTC Manila-Br. 6: March 7, 2016 (Civil Case No. 16-135469).
RTC Br. 6 granted PRC’s Omnibus Motion to Dismiss: Resolution dated August 31, 2017.
CA reversed RTC Br. 6: Decision dated March 10, 2020; denial of reconsideration: September 21, 2020.
Supreme Court decision under review: September 14, 2021 (applies the 1987 Constitution).

Applicable Law and Jurisprudence

Constitution applied: 1987 Philippine Constitution (decision rendered after 1990).
Statute expressly discussed: Republic Act No. 8981 (PRC Modernization Act of 2000).
Controlling jurisprudence and principles cited: standards on mootness and when courts may nonetheless decide (So v. Tacla, Jr.; David v. Macapagal-Arroyo; Vda. de Dabao; Quizon v. COMELEC), authority on declining jurisdiction when no practical relief can be ordered (Philippine Sugar Institute v. Association of Philsugin Employees; Portugues v. Candaba), and other cited authorities in the record.

Factual Background

PSME held national elections in October 2015. Engr. Conti filed a protest alleging irregularities concentrated in the Manila Chapter (late receipt of ballots, alleged bloc voting, identical handwriting, inactive members on voter lists, tally discrepancies). PSME-COMELEC issued an Omnibus Resolution on November 22, 2015 nullifying certain NCR tally sheets (999 votes) and declaring Conti’s group as the winners of the 2016 board of directors; Conti’s group thereafter held an officers’ election on November 25, 2015 where Conti was declared National President and submitted lists to the PRC. In parallel, the outgoing 2015 Board proceeded with a special meeting on November 28, 2015 where Engr. Demdam’s slate elected their own set of officers and claimed the presidency for Demdam.

Procedural History (lower courts and tribunal actions)

Conti’s group filed an intra-corporate case before RTC Manila-Br. 24 seeking validation of the Omnibus Resolution and the November 25, 2015 officers’ election. RTC Br. 24’s August 8, 2016 Decision upheld the Omnibus Resolution as to board membership but voided the November 25, 2015 officers’ election that had declared Conti as National President.
Separately, PSME through Engr. Demdam filed a petition before RTC Manila-Br. 6 for declaration of nullity of PRC Office Order No. 2016-56 (which recognized Conti for purposes of issuing Certificates of Good Standing required for renewal of professional ID cards). The PRC moved to dismiss the nullity petition on grounds of mootness and res judicata based on the RTC Br. 24 decision. RTC Br. 6 granted the PRC’s motion to dismiss on August 31, 2017.
On appeal, the Court of Appeals reversed RTC Br. 6 (March 10, 2020), finding the nullity case was not moot and that res judicata did not apply (differences in parties, causes of action, and reliefs). The CA remanded the case for resolution on the merits. The PRC’s motion for reconsideration before the CA was denied (September 21, 2020).

Issue Presented

Whether the petition for declaration of nullity of PRC Office Order No. 2016-56 pending before RTC Manila-Br. 6 became moot in light of RTC Manila-Br. 24’s decision that voided the November 25, 2015 election of Engr. Conti as PSME National President.

Supreme Court Ruling (holding)

The Supreme Court granted the PRC’s petition for review and reversed the Court of Appeals. The nullity case (Civil Case No. 16-135469) was dismissed as moot. The CA’s decision and resolution were set aside, and the RTC Manila-Br. 6 dismissal was upheld.

Legal Reasoning — Mootness Doctrine Applied

The Court applied the established definition and tests for mootness: a case is moot when supervening events remove any justiciable controversy so that judicial declaration would have no practical effect. The Court reiterated that courts may nonetheless adjudicate otherwise moot cases under four recognized exceptions (grave constitutional violation, exceptional public interest, need to formulate controlling principles, or cases capable of repetition yet evading review), but found none of these exceptions applicable here.

Application of Mootness Principles to the Facts

Absence of a justiciable controversy and ineffectiveness of PRC Office Order No. 2016-56. The Court considered RTC Br. 24’s August 8, 2016 decision—which voided the November 25, 2015 officers’ election—to have rendered PRC Office Order No. 2016-56 ineffective. Office Order No. 2016-56 had recognized Conti "for purposes" of issuing Certificates of Good Standing (COGS) to avoid disruption in renewal of professional identification cards; the subsequent determination by RTC Br. 24 that the officers’ election was void effectively negated the practical significance of the PRC recognition. Thus, the nullity petition could no longer yield any substantial relief.
Nature and purpose of PRC Office Order No. 2016-56. The Court emphasized that the PRC’s recognition was provisional and administrative in nature—intended to ensure continuity in the processing of renewals of professional identification cards, not as a final adjudication of internal corporate officer legitimacy. The PRC itself clarified by letter that its recognition was "w

Case Syllabus (G.R. No. 157384)

Case Caption and Decision

G.R. No. 254282, September 14, 2021, First Division.
Parties: Professional Regulation Commission (PRC), petitioner; Philippine Society of Mechanical Engineers (PSME), respondent.
Opinion penned by Justice Lazaro-Javier; concurrence by Gesmundo, C.J., Caguioa, M. Lopez, and J. Lopez, JJ.
Relief sought: Review of Court of Appeals dispositions in CA-G.R. CV No. 110943 — Decision dated March 10, 2020 reversing the RTC-Manila, Branch 6 dismissal, and Resolution dated September 21, 2020 denying reconsideration.
Final disposition by the Supreme Court: Petition GRANTED; the Court of Appeals Decision (March 10, 2020) and Resolution (September 21, 2020) REVERSED and SET ASIDE; Civil Case No. 16-135469 dismissed for being moot.

Procedural History

October 21–25, 2015: PSME 63rd National Convention and General Membership Meeting; election of 2016 National Board of Directors.
October 26, 2015: Engr. Leandro A. Conti filed letter-protest before PSME-COMELEC alleging irregularities in Manila Chapter ballots and tallying.
November 22, 2015: PSME-COMELEC issued Omnibus Resolution resolving the protest in favor of Engr. Conti, annulling 999 NCR votes and declaring Conti’s group as winners of the 2016 Board of Directors.
November 25, 2015: PSME-COMELEC conducted election for 2016 National Officers where Engr. Conti was elected National President; Conti furnished PRC purported list of 2016 officers.
November 26, 2015: Conti’s group filed an intra-corporate case (raffled to RTC Manila–Br. 24) seeking validation of the November 22 Omnibus Resolution and the November 25 election.
November 28, 2015: Despite Omnibus Resolution, the 2015 Board proceeded with Special Board Meeting; Engr. Murry F. Demdam was elected 2016 PSME National President at that meeting.
December 18, 2015: PRC, through Acting Chairperson Angeline Chua Chiaco, sent a letter acknowledging Engr. Conti as 2016 PSME National President.
February 10, 2016: PRC issued Office Order No. 2016-56 recognizing Engr. Conti “solely for the purpose of issuing Certificates of Good Standing required for the PSME members applications for renewal of their Professional Identification Cards.”
March 7, 2016: PSME (represented by Engr. Demdam) filed petition for declaration of nullity of PRC Office Order No. 2016-56 (raffled to RTC Manila–Br. 6).
August 8, 2016: RTC Manila–Br. 24 rendered Decision in intra-corporate case declaring valid the November 22, 2015 Omnibus Resolution (winners of Board) but voiding the November 25, 2015 election of National Officers (where Conti was declared President); writ of execution issued August 23, 2016.
August 31, 2017: RTC Manila–Br. 6 granted PRC’s Omnibus Motion to Dismiss petition for nullity as moot and on res judicata grounds.
Court of Appeals Decision dated March 10, 2020 reversed RTC-Manila–Br. 6, finding case not moot and remanded for merits; CA denied reconsideration September 21, 2020.
December 29, 2020: Petition for Review on Certiorari filed with the Supreme Court by PRC (via OSG); Supreme Court granted the petition and dismissed Civil Case No. 16-135469 for being moot.

Factual Antecedents (Material Facts)

The PSME convention (Oct 21–25, 2015) elected 15 board members for the 2016 National Board; PSME-COMELEC, through 2015 National President Engr. Pablito Ocampo, confirmed the 2016 board winners on October 25, 2015.
Conti’s protest alleged: Manila Chapter accepted ballots after deadline; 3,500 ballots favored a single slate; ballots exhibited single penmanship and pen usage; sequence of candidates was identical; voter list included inactive members; discrepancies in NCR tallying affecting candidate positions.
PSME Executive Committee invited incoming 2016 Board members to a Special Board Meeting on November 28, 2015 to elect National Officers; PSME-COMELEC initially furnished Conti’s protest to Engr. Demdam’s group and received counter-letters.
PSME National Board Resolution 2015-59 (Nov 14, 2015) directed attendance at Nov 28 Special Board Meeting; PSME-COMELEC instead issued Omnibus Resolution Nov 22, 2015 resolving protest for Conti’s group and annulling certain votes.
Conti’s group’s intra-corporate suit sought validation of the Comelec Omnibus Resolution and the Nov 25, 2015 election of National Officers.
PRC’s Office Order No. 2016-56 directed that only Certificates of Good Standing signed by PSME National President Leandro A. Conti be accepted for renewal of PICs of mechanical engineers, stating recognition of Conti was “in light however of the ensuing conflict within the PSME leadership” and that PSME remains the Accredited and Integrated Professional Organization (AIPO) for mechanical engineers.
PRC clarified by letter dated February 5, 2016 that its recognition was “without prejudice to the resolution of the pending case” before RTC–Br. 24.
PRC later issued Resolution No. 107 Series of 2016 (Aug 5, 2016) suspending implementation of the Certificate of Good Standing requirement for PIC renewal of mechanical engineers, further affecting the relevance of Office Order No. 2016-56.
Subsequent developments: Engr. Conti was appointed Chairman of the Professional Regulatory Board for Mechanical Engineers; by 2019, Engr. Jeffrey F. Singso