REPUBLIC VS MANALO

ISSUE:  Whether or not the CA erred in holding that the Manila  RTC committed grave abuse of discretion in issuing the  joint order? 

FACTS:  Republic of the Philippines, represented in this case by the Anti-Money Laundering Council (AMLC), filed a complaint for civil forfeiture. In the said civil forfeiture cases,  the Republic sought the forfeiture in its favor of certain deposits and government securities maintained in several bank accounts by the defendants therein, which were  related to the unlawful activity of fraudulently accepting investments from the public, in violation of the Securities Regulation Code as well as the Anti-Money Laundering Act of 2001. In a Decision dated May 21, 2009, the CA granted respondents' petition,  ruling that the Manila RTC gravely abused its discretion in denying respondents'  separate motions for intervention. Feeling aggrieved, the Republic moved for  reconsideration which was, however, denied by the CA. 

DECISION:  No. The petition must be dismissed for having  become moot and academic. 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. 

RATIO DECIDENDI:  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.In this case , the Manila RTC's rendition of the Decision dated September 23, 2010 as  well as the Decision dated February 11, 2011 and the Amended Decision dated  May 9, 2011 by virtue of which the assets subject of the said cases were all forfeited  in favor of the government, are supervening events which have effectively rendered  the essential issue in this case moot and academic, that is, whether or not respondents  should have been allowed by the Manila RTC to intervene on the ground that they  have a legal interest in the forfeited assets.