Superseding events have rendered the instant case moot and academic - Supreme Court E-Library -- G.R. NO. 93694: PHILIPPINE COCONUT PRODUCERS FEDERATION, INC. [COCOFED], COCONUT INVESTMENT COMPANY [CIC], COCOFED MARKETING CORPORATION [COCOMARK], MARIA CLARA L. LOBREGAT, BIENVENIDO MARQUEZ, JOSE R. ELEAZAR, JR., DOMINGO ESPINA, JOSE GOMEZ, CELESTINO SABATE, MANUEL DEL ROSARIO, ET AL. V. HONORABLE SANDIGANBAYAN FIRST DIVISION, REPUBLIC OF THE PHILIPPINES AND PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT

Supreme Court E-Library -- G.R. NO. 93694: PHILIPPINE COCONUT PRODUCERS FEDERATION, INC. [COCOFED], COCONUT INVESTMENT COMPANY [CIC], COCOFED MARKETING CORPORATION [COCOMARK], MARIA CLARA L. LOBREGAT, BIENVENIDO MARQUEZ, JOSE R. ELEAZAR, JR., DOMINGO ESPINA, JOSE GOMEZ, CELESTINO SABATE, MANUEL DEL ROSARIO, ET AL. V. HONORABLE SANDIGANBAYAN FIRST DIVISION, REPUBLIC OF THE PHILIPPINES AND PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT


"x x x.

Superseding events have rendered
the instant case moot and academic 

In Mendoza v. Villas,^[15] the Court explained the concept of mootness, citing Gunsi, Sr. v. Commissioners: ^[16] 

In Gunsi, Sr. v. Commissioners, The Commission on Elections, the Court defined a moot and academic case as follows:

A moot and academic case is one that ceases to present a justiciable controversy by virtue of supervening events, so that a declaration thereon would be of no practical value. As a rule, courts decline jurisdiction over such case, or dismiss it on ground of mootness.

Sec. 8, Rule 10 of the Rules of Court specifically provides for the effect of the amendment of pleadings, to wit:

Section 8. Effect of amended pleadings. — An amended pleading supersedes the pleading that it amends. However, admissions in superseded pleadings may be received in evidence against the pleader, and claims or defenses alleged therein not incorporated in the amended pleading shall be deemed waived.

Thus, the Court considered the issue of whether an original complaint should have been dismissed for having become moot with the admission of an amended complaint in Lu v. Lu Ym, Sr.^[17]  The Court ruled in this wise: 

With the issue of admission of the amended complaint resolved, the question of whether or not the original complaint should have been dismissed was mooted. Section 8, Rule 1.0 of the Rules of Court specifically provides that an amended pleading supersedes the pleading that it amends. In this case, the original complaint was deemed withdrawn from the records upon the admission of the amended complaint. This conclusion becomes even more pronounced in that the RTC already rendered a decision on the merits of the said amended complaint, not to mention the Lu Ym father and sons' concurrence in the mootness of the issue in the instant petition. (Emphasis supplied.)

Evidently, with the admission of the subdivided complaints in the instant case, the original complaint in CC 0033 is deemed withdrawn from the records, such that CC 0033 no longer exists. Correlatively, the issues pending in CC 0033 must be likewise considered moot and academic.

x x x."