G.R. No. L-38435 February 25, 1975
VICTORIO V. MULATO, petitioner, vs. ARTEMIO R. SALDIVAR, respondent.

FACTS

Petitioner Victorio V. Mulato, the incumbent Chief of Police of Pozorrubio, Pangasinan, was initially suspended for sixty days effective June 28, 1968, based on an administrative charge. Upon the expiration of this period on August 28, 1968, he reported for duty. However, respondent Municipal Mayor Artemio R. Saldivar ordered his suspension for an indefinite period pending the termination of the administrative case. A subsequent second administrative complaint led to a third suspension order. Consequently, Mulato filed a petition for mandamus with the Court of First Instance to compel his reinstatement. The trial court ruled in his favor, ordering reinstatement. Mayor Saldivar appealed this decision to the Court of Appeals.
The Court of Appeals, finding that only a question of law was involved, elevated the case to the Supreme Court. During the pendency of this appeal, the Supreme Court required the parties to manifest the status of the administrative cases. It was then revealed that the National Police Commission had already rendered a decision on July 31, 1973, in Administrative Case No. 463, finding Mulato guilty of serious irregularity and dismissing him from the service. Mulato’s motion for reconsideration of this dismissal was denied by the National Police Commission Adjudication Board on December 10, 1974.

ISSUE

Whether the petition for mandamus seeking reinstatement has been rendered moot and academic by the supervening decision of the National Police Commission dismissing Mulato from the service.

RULING

Yes, the petition is dismissed for being moot and academic. The core legal principle applied is that courts will not determine a case where a supervening event has occurred, rendering a judicial resolution unnecessary or incapable of providing any actual relief. The original action was a mandamus proceeding to compel Mulato’s reinstatement to the position of Chief of Police. This relief sought is predicated on the validity of his continued right to hold that office.
The supervening decision of the National Police Commission, a competent administrative body, which found Mulato guilty and ordered his dismissal from the service, fundamentally altered the factual and legal landscape of the case. This dismissal constitutes a definitive termination of his employment. Even if the Supreme Court were to rule on the procedural validity of the earlier suspension orders contested in the mandamus action, such a ruling would be ineffectual. It could not result in Mulato’s reinstatement because the final administrative dismissal order constitutes a separate and valid legal ground for his separation from service, which is no longer connected to the suspension orders under review. Therefore, any decision on the merits of the mandamus petition would be an academic exercise without practical legal consequence. The case is thus moot.