Pagdanganan vs. Court of Appeals

G.R. No. 202678, September 05, 2018

Third Division

Leonen, J

Solid Guaranty is a domestic corporation engaged in the insurance business. Solid Guaranty, through Pagdanganan, a minority stockholder, filed a complaint for interpleader before the RTC-Manila. The complaint was filed because of the alleged conflicting claims between Ma. Susana A.S. Madrigal, Ma. Ana A.S. Madrigal, and Ma. Rosa A.S. Madrigal (collectively, the Madrigals), and Citibank over the shares of stock previously held by the late Antonio P. Madrigal.

The petitioner filed a Petition for Mandamus seeking to compel the CA to resolve the Petition in CAG.R. SP No. 104291, alleging that the CA committed inordinate delay in violation of the right to speedy disposition of cases.

Question: When does a case become petition moot and academic?

In Baldo v. Commission on Elections stated:

A case becomes moot when there is no more actual controversy between the parties or no useful purpose can be served in passing upon the merits. Courts will not determine a moot question in a case in which no practical relief can be granted. It is unnecessary to indulge in academic discussion of a case presenting a moot question, as a judgment thereon cannot have any practical legal effect or, in the nature of things, cannot be enforced. Xxx

In this Petition, petitioners prayed for the issuance of a writ of mandamus to compel the Court of Appeals to resolve CA-G.R. SP No. 104291. However, the Court of Appeals already rendered a Decision in CA-G.R. SP No. 104291 on February 8, 2013. It also resolved petitioners' Motion for Reconsideration on March 10, 2014. Despite the occurrence of these subsequent events, petitioners, in their Memorandum, reiterated their prayer for this Court to compel the Court of Appeals to resolve CA-G.R. SP No. 104291.

Any issuance of a writ of mandamus in this case, however, becomes an exercise in futility. The Court of Appeals cannot be compelled to resolve a case it has already fully resolved. This Petition must be dismissed for being moot.

Question: Did the CA commit an inordinate delay in resolving the petition in CAG.R. SP No. 104291?

No.

Even assuming that this Court could still pass upon the substantive issue in this case, the Petition would still be denied for lack of merit. It was only on December 14, 2012 that the Court of Appeals declared with finality that CA-G.R. SP No. 104291 was deemed submitted for decision.

Under Section 15(1), Article VIII of the Constitutionthis provision, the Court of Appeals is given a 12-month period to resolve any case that has already been submitted for decision. Any case still pending 12 months after submission for decision may be considered as delay. The parties may file the necessary action, such as a petition for mandamus, to protect their constitutional right to speedy disposition of cases.

In this case, however, petitioners' invocation of the right to speedy disposition of cases is misplaced since the Court of Appeals has resolved the petition in a timely manner within the period provided by law.