6/5/2020
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similar cases that seek injunction from regular courts, the resolution of the instant
Petition is necessary in settling once and for all which between the DOLE Secretary and
the RTC has jurisdiction over actions assailing a POEA Order that involves immediate
enforcement of penalties for serious offenses such as cancellation of license. The
Republic likewise buttresses its other arguments that Principalia failed to exhaust
administrative remedies when it directly filed the injunction case with the RTC and that
it committed forum-shopping.[23]
Issue
The central issue in this case is whether the RTC has jurisdiction over the injunction
case.
Our Ruling
At the outset, it must be noted that the Petition is dismissible for being moot and
academic. It should be recalled that what impelled Principalia to file the main action for
injunction was the June 8, 2009 POEA Order directing the immediate cancellation of its
license. Since Principalia could not then engage in recruitment activities because of the
said Order, it resorted to the RTC to question and seek to enjoin such immediate
cancellation for the obvious reason that it wanted to continue the operation of its
business. Significantly, however, Principalia, to date, is a POEA-accredited recruitment
agency licensed to do business until April 1, 2016.[24] As things stand, therefore,
Principalia has no more claim for relief against POEA since this has been mooted by the
latter's renewal of its license to do business. In fact and as mentioned, Principalia
already moved for the dismissal of the injunction case before the RTC which the said
court correctly granted.
"A case becomes moot and academic when, by virtue of supervening events, there is
no more actual controversy between the parties and no useful purpose can be served in
passing upon the merits."[25] In Arevalo v. Planters Development Bank,[26] the Court
expounded:
The Constitution provides that judicial power 'includes the duty of the courts
of justice to settle actual controversies involving rights which are legally
demandable and enforceable.' The exercise of judicial power requires
an actual case calling for it. The courts have no authority to pass upon
issues through advisory opinions, or to resolve hypothetical or feigned
problems or friendly suits collusively arranged between parties without real
adverse interests. Furthermore, courts do not sit to adjudicate mere
academic questions to satisfy scholarly interest, however intellectually
challenging. As a condition precedent to the exercise of judicial
power, an actual controversy between litigants must first exist. An
actual case or controversy involves a conflict of legal rights, an assertion of
opposite legal claims susceptible of judicial resolution, as distinguished from
a hypothetical or abstract difference or dispute. There must be a contrariety
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