G.R. No. L-27665. May 31, 1977. PHILIPPINE VIRGINIA TOBACCO ADMINISTRATION, petitioner, vs. HON. ANDRES REYES, as Judge, Court of First Instance of Rizal, and ALTO SALES CORPORATION, respondents.
FACTS

The Philippine Virginia Tobacco Administration (PVTA) filed this petition for certiorari to nullify a writ of preliminary mandatory injunction issued by the Court of First Instance of Rizal in a civil case for specific performance filed by Alto Sales Corporation. The lower court also issued an order requiring PVTA’s officer to show cause why he should not be cited for contempt for non-compliance. This Court initially issued a restraining order but later lifted it and denied PVTA’s prayer for a preliminary injunction. Subsequently, while this petition was pending, the trial court rendered a decision on the merits of the main case for specific performance, awarding damages to Alto Sales. The parties then filed conflicting manifestations regarding whether this certiorari petition had become moot.
Alto Sales initially urged the Supreme Court to decide the petition on its merits but later shifted its position, stating that the injunction had not been implemented, the subject tobacco had deteriorated, and it was opting for the damages already awarded by the lower court. It then reversed again, requesting a final resolution. PVTA consistently joined in submitting the case for a decision on the merits. The Supreme Court noted the curious absence of any showing that Alto Sales had taken steps to enforce the challenged writ of preliminary injunction or to seek sanctions for its non-implementation.

ISSUE

Whether the petition for certiorari assailing the propriety of the writ of preliminary mandatory injunction has been rendered moot and academic.

RULING

Yes, the petition is dismissed for being moot and academic. The legal logic is clear: the sole issue in this special civil action for certiorari is limited to whether the trial court committed grave abuse of discretion in issuing the preliminary mandatory injunction. This issue has been overtaken by events and rendered inconsequential. The trial court has already decided the main action for specific performance on its merits, and its decision is now in the process of appeal. The Supreme Court cannot preempt the appellate court’s jurisdiction over that appeal. Furthermore, the factual circumstances demonstrate mootness. Private respondent itself admitted the injunction was never implemented, the perishable subject matter had deteriorated, and it had opted to claim the damages awarded in the main decision. With no active enforcement of the challenged writ being sought, any ruling on its propriety would be purely academic and serve no practical purpose. Certiorari is a remedy for correcting jurisdictional errors when there is no plain, speedy, and adequate remedy; it is not for deciding abstract questions. Since the interim relief sought has been superseded by a final judgment and the parties’ subsequent conduct, the case is moot.