**Eduardo T. Abad vs. Leonardo Biason and Gabriel A. Magno: A Dispute Over Guardianship**
### Facts:
This case arose from a petition for guardianship filed by Eduardo Abad (petitioner) over Maura B. Abad (Maura), his elderly and frail aunt, with the Regional Trial Court (RTC) of Dagupan City, on March 19, 2007. Abad, alleging Maura’s incapacity due to advanced age and health conditions, proposed himself as a suitable guardian for both her person and properties. However, his petition encountered opposition from Leonardo Biason (Biason), another nephew of Maura, who contested Abad’s qualifications based on his non-residence in Maura’s locality and claimed he had previously been granted a power of attorney by Maura over her properties.
The RTC denied Abad’s petition, appointing Biason as Maura’s guardian instead, on the grounds that Biason’s closer proximity to Maura made him a more suitable guardian. Abad’s subsequent motion for reconsideration was denied, prompting him to appeal to the Court of Appeals (CA). The CA affirmed the RTC’s decision, leading Abad to elevate the matter to the Supreme Court via a Petition for Review on Certiorari, asserting violations of due process and arguing against the disqualification based on residency. While the petition was pending, Biason died, leading Maura to file a motion suggesting that Biason’s death rendered the case moot.
### Issues:
1. Did the CA commit an error in affirming the RTC’s decision to disqualify Abad as guardian based solely on residence while overlooking his qualifications and Maura’s preference?
2. Did Biason’s death render the dispute moot, thus negating the need for further judicial scrutiny?
### Court’s Decision:
The Supreme Court ultimately dismissed the petition on the grounds of mootness, following Biason’s death. The Court observed that the crux of the petition revolved around the legality of Biason’s appointment as Maura’s guardian. Given that the guardian-ward relationship is extinguished upon the death of either party, Biason’s passing obviated the need for a determination on the merits of his appointment. The Court agreed with the parties that resolving the issues raised would no longer provide practical relief or bear significance.
### Doctrine:
The case reiterated the doctrine that a judicial controversy becomes moot and academic when it ceases to present a justiciable controversy, making a court’s decision pointless as it would offer no practical relief to any party involved. Also, it underscored the principle that the death of a guardian or ward automatically terminates the guardianship relationship.
### Class Notes:
– **Moot and Academic Principle**: When an event occurs that resolves the issue or makes it irrelevant, the case is deemed moot, and courts typically dismiss the case as there is no longer an actual controversy requiring resolution.
– **Termination of Guardianship**: The guardianship relationship is terminated upon the death of the guardian or the ward, as per the established legal principles, without the need for judicial intervention.
– **Qualifications for Guardianship**: The case briefly touches upon the qualifications for guardianship, emphasizing not just the geographical proximity but also the moral character, ability, and judgment to manage the ward’s affairs effectively.
### Historical Background:
This case illustrates a typical judicial approach to guardianship disputes, balancing between legal procedures, the qualifications and preferences for a guardian, and the supervening events that could render a dispute moot. It reflects the challenges courts face in guardianship issues, particularly in determining the most suitable guardian for the ward, and highlights the importance of proximity and the guardian’s capability to manage the ward’s affairs effectively.
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