National Power Corp. v. Veyra
REITERATIONFacts
The Antecedents: The City of Baguio was ordered by the Court of First Instance (CFI) of Manila to pay the National Power Corporation (NPC) P240,000.00 for unpaid electric charges and generator rentals. This decision became final, and a writ of execution was issued. The Sheriff of Baguio City, in compliance, garnished P239,589.80 of Baguio City's cash deposits held by the Philippine National Bank (PNB) in Baguio. Procedural History: On June 12, 1959, Baguio City filed a complaint (Civil Case No. 866) against NPC, PNB, and the Sheriff in the CFI of Baguio City, seeking to declare the garnishment illegal and to restrain further actions. On the same day, the CFI of Baguio City issued a preliminary mandatory injunction ordering the restoration and maintenance of the status quo of the garnished bank deposits. NPC's motions for reconsideration and dismissal of the case on grounds of lack of jurisdiction and cause of action were denied. The Petition: NPC filed the instant petition for certiorari with the Supreme Court, seeking to annul the preliminary mandatory injunction issued by the respondent judge, declare the CFI of Baguio City without jurisdiction over Civil Case No. 866, and compel its dismissal. The core issue is whether property already under garnishment by one court can be subjected to the jurisdiction of another court in an independent suit questioning the legality of the garnishment, particularly when the property is allegedly exempt from execution.
Issue(s)
Whether the Court of First Instance of Baguio City has jurisdiction to interfere with property already under garnishment by the Court of First Instance of Manila. Whether a preliminary mandatory injunction may be issued by a court of coordinate jurisdiction to restrain actions taken pursuant to a writ of execution issued by another court.
Ruling
The Supreme Court set aside the preliminary mandatory injunction issued by the respondent court and enjoined further proceedings in Civil Case No. 866. The Court held that the CFI of Baguio City lacked jurisdiction to interfere with property under custodia legis of the CFI of Manila.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Court of First Instance of Baguio City did not have jurisdiction over the garnished property. The Court explained that when property is levied upon in a garnishment proceeding to satisfy a writ of execution, it is brought into custodia legis, meaning it is under the sole control of the court that issued the writ. In this case, the property was under the custodia legis of the CFI of Manila, which had issued the writ of execution. Therefore, the CFI of Baguio City, a court of coordinate jurisdiction, could not interfere with the Manila court's jurisdiction. The principle aims to avoid conflicts of power between courts of equal authority and ensure the orderly administration of justice. Any challenge to the legality of the levy or the property's exemption should have been raised before the CFI of Manila, which had the authority to address such matters. On Issue 2: The Supreme Court held that the preliminary mandatory injunction issued by the respondent court was improper and should be set aside. The Court reiterated the principle that no court has the authority to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction that possesses equal power to grant the relief sought. Allowing coordinate courts to interfere with each other's orders through injunctions would inevitably lead to confusion and seriously hinder the proper administration of justice. The respondent court's reasoning that it should grant relief due to an allegedly illegal service of the writ was not upheld, as there was a more appropriate procedural remedy available in the court that issued the writ.
Main Doctrine
The principle of custodia legis dictates that property seized by virtue of a writ of execution or attachment is under the exclusive jurisdiction of the court that issued the writ. Consequently, no court of coordinate jurisdiction may interfere with such custody or issue injunctions to restrain actions taken pursuant to the writ, as this would lead to conflicts of power and hinder the proper administration of justice. Any challenges to the legality of the levy or the exemption of the property must be raised before the court that has custody of the property.