TL;DR
The Supreme Court dismissed the Social Security System’s (SSS) petition challenging a writ of possession issued to the National Grid Corporation of the Philippines (NGCP) in an expropriation case. NGCP had sought to expropriate SSS land, but later withdrew the expropriation complaint. The Supreme Court held that because NGCP withdrew the main expropriation case in the lower court, SSS’s challenge to the interlocutory writ of possession became moot. This means the court saw no practical value in resolving the issue since the underlying expropriation action was already terminated. The ruling underscores that courts will generally not decide on issues that no longer present a live controversy or offer practical relief, promoting judicial efficiency and preventing advisory opinions.
When the Case Ends Before the Court Decides: Mootness in Expropriation Disputes
This case, Social Security System vs. Hon. Gina M. Bibat-Palamos and National Grid Corporation of the Philippines, arose from a special civil action for certiorari initiated by the SSS. SSS questioned orders from the Regional Trial Court (RTC) of Pasay City which granted NGCP a writ of possession over SSS property. NGCP needed the land for its Pasay 230kV Substation Project, crucial for Manila’s growing electricity demands. The RTC, relying on Republic Act No. 10752, which streamlines right-of-way acquisition for national government projects, issued the writ after NGCP deposited the zonal valuation of the property. SSS contested this, arguing that NGCP, a private corporation, could not expropriate government property and questioned the applicability of RA 10752. However, a significant turn occurred when NGCP opted to withdraw its expropriation complaint in the RTC due to project uncertainties, leading to the central question before the Supreme Court: whether SSS’s petition should be dismissed due to mootness.
The Supreme Court’s resolution hinged on the principle of mootness. The Court emphasized that an order for a writ of possession in expropriation is interlocutory, meaning it is provisional and dependent on the main expropriation case. Since NGCP withdrew the expropriation complaint, the foundation for the writ of possession crumbled. The Court cited established jurisprudence, particularly Philippine Veterans Bank v. Court of Appeals, reiterating that a case becomes moot when it no longer presents a justiciable controversy due to supervening events. In such situations, any judicial pronouncement would lack practical effect. The Court explained:
A case or issue is considered moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication of the case or a declaration on the issue would be of no practical value or use. In such instance, there is no actual substantial relief which a petitioner would be entitled to, and which would be negated by the dismissal of the petition. Courts generally decline jurisdiction over such case or dismiss it on the ground of mootness. This is because the judgment will not serve any useful purpose or have any practical legal effect because, in the nature of things, it cannot be enforced.
Applying this doctrine, the Supreme Court found that resolving SSS’s petition, which challenged the writ of possession, would be pointless because the underlying expropriation case had been dismissed by the RTC. The Court acknowledged exceptions to the mootness doctrine, such as instances involving grave violations of fundamental rights, or when the issue is capable of repetition yet evading review. However, it found none of these exceptions applicable in this case. The practical consequence of the RTC’s dismissal of the expropriation case and the Supreme Court’s application of mootness is that the legal dispute over the writ of possession effectively ended without a definitive ruling on the merits of SSS’s arguments regarding NGCP’s expropriation powers or the applicability of RA 10752 in this context. The Supreme Court prioritized judicial economy, declining to issue an advisory opinion on a moot issue. This decision reinforces the procedural principle that appellate courts generally refrain from resolving challenges to interlocutory orders when the main case is no longer active, ensuring that judicial resources are focused on live controversies with tangible outcomes.
FAQs
| What was the key issue in this case? | The central issue was whether the Supreme Court should resolve SSS’s petition challenging the writ of possession, even after NGCP withdrew the expropriation case in the lower court, rendering the issue moot. |
| What is a writ of possession in expropriation cases? | A writ of possession is an interlocutory order issued by the court allowing the expropriating entity to take possession of the property after depositing the initial valuation, even before the final determination of just compensation. |
| What does ‘mootness’ mean in legal terms? | A case is considered moot when it no longer presents a live controversy because of events that occurred after the case was filed, making a judicial decision practically unnecessary or without effect. |
| Why did the Supreme Court dismiss SSS’s petition? | The Court dismissed the petition because NGCP withdrew the main expropriation case, making the issue of the writ of possession moot. Resolving the petition would have been pointless as the underlying dispute was no longer active. |
| What is the practical implication of this ruling? | This ruling reinforces the principle of judicial efficiency by preventing courts from deciding moot cases. It clarifies that challenges to interlocutory orders in expropriation become irrelevant upon dismissal of the main expropriation action. |
| What is an interlocutory order? | An interlocutory order is a temporary or provisional order issued during the course of a case, which does not finally resolve the entire case but deals with preliminary or intermediate matters. |
For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: G.R. No. 231145, June 26, 2023, Supreme Court Second Division
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