ROMEO D. LONZANIDA, PETITIONER, VS. THE HON. SANDIGANBAYAN, (FOURTH DIVISION), RESPONDENT.

Lonzanida versus Sandiganbayan

The Case

This is a petition for the writs of certiorari and prohibition filed by Romeo D. Lonzanida, then the mayor of San Antonio, Zambales, against the Fourth Division of the Sandiganbayan. Lonzanida had been convicted of ten counts of falsification of public document. After his conviction became the subject of a granted motion for new trial, the Sandiganbayan suddenly issued a resolution declaring its original judgment final and ordering his arrest, instead of rendering a new judgment. Lonzanida asked the Supreme Court to set that resolution aside. The case matters to a reviewee because it is the Court's cleanest illustration of mootness: a supervening event that gives the petitioner exactly what he prayed for strips the Court of any live controversy to resolve.

Procedural History

In 1988, the Office of the Special Prosecutor charged Lonzanida in the Sandiganbayan with ten counts of falsification of public document. He pleaded not guilty and trial ensued. On 20 October 2000, the Sandiganbayan rendered judgment finding him guilty as charged and sentencing him accordingly. Lonzanida sought reconsideration, and later moved that his motion for reconsideration be treated as a motion for new trial based on newly discovered evidence. The Sandiganbayan denied both motions. On reconsideration of the denial of the motion for new trial, the Sandiganbayan granted the motion, in what it called the supreme interest of justice, and conducted hearings to receive the testimonies of Lonzanida's witnesses. The Office of the Special Prosecutor challenged that grant before the Supreme Court, but the First Division dismissed the petition, and denied reconsideration with finality.

After the hearings, the Sandiganbayan required the parties to submit memoranda and scheduled the promulgation of judgment for 2 December 2002, later moved to 3 March 2003. Instead of promulgating a new judgment, however, the Sandiganbayan issued a resolution dated 21 January 2003 declaring its decision of 20 October 2000 final and ordering Lonzanida's arrest. Both Lonzanida and the Office of the Special Prosecutor moved for clarification, with the prosecution itself manifesting that a new judgment should be rendered taking into account the new-trial evidence. The Sandiganbayan cancelled the 3 March 2003 promulgation until further directives.

On 10 March 2003, Lonzanida filed this petition to set aside the 21 January 2003 Resolution, praying also for an injunctive order. The Supreme Court issued the injunctive order and required the Sandiganbayan to comment. In its comment, the Sandiganbayan manifested that it had already prepared the draft of a new decision. On 25 July 2003, it promulgated that decision, again finding Lonzanida guilty of ten counts of falsification and imposing the same penalty, and in the same ruling it set aside the 21 January 2003 Resolution. The Court then resolved to dismiss the petition as moot. Lonzanida separately appealed the 25 July 2003 Decision, but the First Division denied his petition, and his motion for reconsideration was submitted for resolution.

Facts

Romeo Lonzanida, then mayor of San Antonio, Zambales, was charged in 1988 before the Sandiganbayan with ten counts of falsification of public document under the Revised Penal Code. He pleaded not guilty and went to trial. On 20 October 2000, the Sandiganbayan convicted him on all ten counts, sentencing him in each case to imprisonment of four years and one day of prision correccional as minimum to eight years and one day of prision mayor as maximum, and to pay a fine of 5,000 pesos in each case, without subsidiary imprisonment in case of insolvency.

Lonzanida sought reconsideration, then moved that his motion be treated as a motion for new trial based on newly discovered evidence. The Sandiganbayan denied both, but on reconsideration granted the motion for new trial in the supreme interest of justice and received his witnesses' testimonies. It then directed the parties to submit memoranda and set the promulgation of judgment for 2 December 2002, later moved to 3 March 2003.

Instead of a new judgment, the Sandiganbayan issued the 21 January 2003 Resolution declaring its 20 October 2000 Decision final and executory and issuing a warrant of arrest, reasoning that it could not, even in the exercise of discretion, modify a decision that had long become final. Both sides sought clarification, and the prosecution itself asked for a new judgment reflecting the new-trial evidence. The Sandiganbayan cancelled the scheduled promulgation. On 25 July 2003, it promulgated a new Decision again convicting Lonzanida on all ten counts and imposing the same penalty, and expressly set aside the 21 January 2003 Resolution.

Issues

• Whether or not the petition to set aside the Sandiganbayan's 21 January 2003 Resolution has been rendered moot by the Sandiganbayan's subsequent Decision of 25 July 2003, which set aside that Resolution and rendered a new judgment after new trial.
• Whether or not the grant of new trial vacated the Sandiganbayan's Decision of 20 October 2000, such that the 21 January 2003 Resolution declaring that Decision final was improper.

Applicable Provisions

The petition was brought under Rule 65 of the 1997 Rules of Civil Procedure, which governs the special civil actions of certiorari and prohibition. The Court's resolution of the case turns on the procedural consequence of a supervening event, not on the text of the Rule, so the decision quotes no provision verbatim. The charge itself was for falsification of public document defined and punished under Article 171 of the Revised Penal Code, and the penalty imposed in each count was fixed under the Indeterminate Sentence Law. These provisions identify the offense and the sentence but do not supply the ratio of the ruling.

Ruling

On the first issue, the Court held that the petition had been rendered moot. The object of the petition was to set aside the 21 January 2003 Resolution declaring the 20 October 2000 Decision final, on the ground that the grant of new trial had vacated that Decision. That state of affairs came to pass when the Sandiganbayan promulgated its 25 July 2003 Decision, which not only found Lonzanida guilty as charged but also set aside the 21 January 2003 Resolution. The Court described the effect in these words:

This supervening event effectively mooted the petition, rendering the issues raised academic and the relief prayed for superfluous.

On the second issue, the Court did not reach the merits. Because the Sandiganbayan itself had already set aside the challenged Resolution and rendered a new judgment after receiving the new-trial evidence, there was no longer any live controversy for the Court to resolve. The Court noted that it had earlier resolved to dismiss the petition for having been rendered moot by the Decision of 25 July 2003, and it confirmed that disposition.

Doctrine

A petition is moot when a supervening event occurs that grants the petitioner the very relief he prays for, so that the issues raised become academic and the relief sought becomes superfluous. Courts do not resolve moot questions; the case is dismissed. Applied here, the grant of a motion for new trial sets aside the original judgment and requires the trial court to render a new judgment on the evidence received, so a resolution declaring the original judgment final while new-trial proceedings are pending is precisely the wrong the petitioner assails. When the trial court itself later sets that resolution aside and promulgates a new judgment, the petition challenging the resolution loses its object. A reviewee should link this to Rule 65: certiorari and prohibition lie only where there is a live tribunal act to annul or restrain, and once that act is undone by the respondent's own subsequent action, the extraordinary writs have nothing left to operate on.

Disposition

The Supreme Court dismissed the petition for having been rendered moot by the Sandiganbayan's Decision of 25 July 2003, which set aside the challenged Resolution.

Remember This

Memorize the line: a supervening event that grants the relief prayed for renders the petition moot, the issues academic, and the relief superfluous. Examiners use this case to test mootness and the effect of a grant of new trial on the finality of a judgment, often pairing it with the rule that courts will not decide academic questions.