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ALAN F. PAGUIA v. OFFICE OF PRESIDENT

FACTS:

Petitioner Alan F. Paguia filed a petition to invalidate President Gloria Macapagal-Arroyo's nomination of respondent Hilario Davide as Permanent Representative to the United Nations (UN). Petitioner argued that Davide was disqualified from holding the post due to his age, which exceeded the mandatory retirement age for officers and employees of the Department of Foreign Affairs (DFA). Respondents challenged petitioner's standing to bring the suit and argued that the retirement age provision applied only to career diplomats and not to non-career appointees like Davide.

ISSUES:

  1. Does petitioner have standing to bring the suit?

  2. Is Davide disqualified from holding the post due to his age?

RULING:

  1. The Supreme Court dismissed the petition without reaching the merits of the case due to the lack of a case or controversy. The Court found that petitioner lacked capacity to sue and that the case had become moot. The Court ruled that petitioner's citizenship and taxpayer status did not give him standing to bring the suit, as none of his allegations raised issues of "transcendental" importance calling for urgent resolution. The Court also noted that there were DFA personnel with a more direct and specific interest to bring the suit. Additionally, the Court found that petitioner's suspension from the practice of law barred him from bringing legal actions. Lastly, the Court considered the resignation of respondent Davide from his post, rendering the case academic and the relief prayed for moot. Thus, the Court dismissed the petition.

PRINCIPLES:

  • Citizen standing in suits of "transcendental" importance requires the character of funds or assets involved in the controversy, a clear disregard of constitutional or statutory prohibition, and the lack of any other party with a more direct and specific interest to bring the suit.

  • Taxpayer standing is granted to question appropriations for expenditures claimed to be unconstitutional or illegal and requires the illegality of the disbursement of public funds.

  • An incapacity to bring legal actions due to an individual's suspension from the practice of law bars them from engaging in activities that require the application of law, legal procedure, knowledge, training, and experience.

  • A case becomes moot and the relief prayed for becomes moot when a supervening event occurs, such as the resignation of a respondent from the position in question.