Case Summary (G.R. No. 254282)
Petitioner and Respondent
Petitioner: Professional Regulation Commission (PRC)
Respondent: Philippine Society of Mechanical Engineers (PSME), represented by Engr. Murry F. Demdam
Key Dates
• October 21–25, 2015: PSME 63rd National Convention and Board election
• November 22 & 25, 2015: PSME-COMELEC Omnibus Resolution and officer election favoring Conti
• December 18, 2015 & February 10, 2016: PRC recognition by Office Order No. 2016-56 of Conti as PSME President
• August 8, 2016: RTC Branch 24 decision in intra-corporate suit voiding Conti’s officer election
• August 31, 2017: RTC Branch 6 dismissal of petition for nullity as moot and res judicata
• March 10, 2020 & September 21, 2020: Court of Appeals decision reversing dismissal and denial of reconsideration
• September 14, 2021: Supreme Court decision
Applicable Law
• 1987 Philippine Constitution (decision date post-1990)
• Republic Act No. 8981 (PRC Modernization Act of 2000)
Antecedent Facts
- PSME held its national convention and elected a Board (Oct. 25, 2015) under Engr. Ocampo’s supervision.
- Engr. Conti filed a letter-protest alleging irregularities in the Manila Chapter ballots.
- Despite scheduled special meeting (Nov. 28, 2015) and Demdam’s group hand-carrying counter-letters, PSME-COMELEC issued an Omnibus Resolution (Nov. 22) annulling 999 NCR votes and declaring Conti’s slate winners.
- PSME-COMELEC then conducted officer elections (Nov. 25) electing Conti as National President.
- Conti furnished PRC copies of his purported officers; Demdam’s group filed an intra-corporate suit in RTC Branch 24.
- Branch 24 upheld the November 22 Omnibus Resolution but voided the November 25 officer election.
- PRC Acting Chairperson Chiaco issued Office Order No. 2016-56 recognizing Conti for issuance of Certificates of Good Standing (COGS) to facilitate license renewals.
Procedural History
• March 7, 2016: PSME filed a petition before RTC Branch 6 to nullify PRC Office Order No. 2016-56 for lack of authority.
• RTC Branch 24 (Aug. 8, 2016) decided intra-corporate dispute—invalidating Conti’s officer election.
• PRC, via OSG, moved to dismiss the nullity petition in RTC Branch 6 as moot and barred by res judicata.
• RTC Branch 6 (Aug. 31, 2017) granted the motion, dismissing the nullity petition.
• Court of Appeals (Mar. 10, 2020) reversed, holding neither mootness nor res judicata applied, and remanded for merits.
• CA denied reconsideration (Sept. 21, 2020).
• PRC filed a petition for certiorari in the Supreme Court.
Issue
Whether the petition to declare PRC Office Order No. 2016-56 null has been rendered moot by the RTC Branch 24 decision invalidating Conti’s election as PSME National President.
Ruling
- Mootness Doctrine – A controversy becomes moot when supervening events render any practical relief impossible. Here, the Branch 24 decision voided the very officer election that Office Order
Case Syllabus (G.R. No. 254282)
Facts and Antecedents
- From October 21–25, 2015, PSME held its 63rd National Convention and General Membership Meeting, including elections for the 2016 Board of Directors and Officers.
- On October 25, 2015, Engr. Pablito Ocampo, the 2015 PSME National President, announced 15 winners for the Board of Directors.
- On October 26, Engr. Leandro A. Conti filed a letter-protest alleging irregularities in the Manila Chapter ballots (late receipt, uniform penmanship, inactive members, vote discrepancies).
- The 2015 Board scheduled a Special Meeting for November 28, 2015, to elect Officers; PSME-COMELEC furnished Engr. Murry F. Demdam’s group with Conti’s protest on November 7.
- On November 14, 2015, the Board passed Resolution 2015-59 directing attendance at the Special Meeting; two weeks later, the COMELEC issued an Omnibus Resolution (November 22, 2015) annulling 999 NCR votes and declaring Conti’s slate as the new Board.
- On November 25, 2015, COMELEC conducted the Officers election; Conti was proclaimed National President and reported to PRC on November 26.
- Conti’s group filed an intra-corporate suit (RTC Manila-Br. 24) praying for validation of the Omnibus Resolution and November 25 election; concurrently, the Board held its Special Meeting (November 28), electing Demdam as President.
- On December 18, 2015, Acting PRC Chair Chiaco sent a letter recognizing Conti as 2016 President; PSME (Demdam) sought its recall, but on February 10, 2016, PRC issued Office Order No. 2016-56 provisionally recognizing Conti for purposes of issuing Certificates of Good Standing (COGS) n