Samar Mining Co. v. Arnado
REITERATIONFacts
1. The Antecedents: Respondent Rufino Abuyen filed a claim for compensation with the Workmen's Compensation Commission, alleging a disease contracted while in the service of petitioner Samar Mining Co., Inc. Petitioner received a notice for a hearing on this claim, scheduled in Catbalogan, Samar. Petitioner questioned the validity and authority of the notice and the hearing, asserting that the authority rested with the Department of Labor Regional Office No. VI in Cebu City, not the assigned Labor Attorney. Despite this, the hearing proceeded without petitioner's appearance, resulting in a decision by respondent Tan finding Abuyen employed as a capataz from August 1949 to March 1956, suffering from pulmonary tuberculosis aggravated by midnight labor, and ordering petitioner to pay compensation. 2. Procedural History: Following the decision by respondent Tan, petitioner filed a motion for reconsideration and reopening of the case with the Regional Office, citing lack of authority. This motion was denied. Consequently, petitioner initiated a certiorari and prohibition action with preliminary injunction in the Court of First Instance of Manila against respondents Arnado, Tan, and Abuyen. The grounds for this action were that respondents Arnado and Tan acted without jurisdiction and/or with grave abuse of discretion in summoning parties, conducting the hearing, rendering the decision, and denying the motion to reopen. The lower court issued the preliminary injunction but subsequently dismissed the case on the ground of wrong venue. 3. The Petition: The petitioner-appellant seeks reversal of the dismissal order, arguing that the Court of First Instance of Manila had jurisdiction to hear the case. The core of the dispute lies in the interpretation of Rule 67, Section 4 of the Rules of Court, concerning where a petition for certiorari and prohibition may be filed. Petitioner contends that Rule 5, Section 1, which allows actions to be commenced where the plaintiff resides, governs venue. Respondents, and the lower court, maintain that Rule 67, Section 4, mandates filing in the Court of First Instance having jurisdiction over the officer or entity whose acts are being challenged, which in this case is the Court of First Instance of Cebu, where Regional Office No. VI is located. The petitioner's appeal hinges on whether the venue provision in Rule 67 refers to jurisdiction over the subject matter or jurisdiction over the person/entity, and whether Rule 5's general venue rule for civil actions applies.
Issue(s)
Whether the Court of First Instance of Manila has the proper venue to entertain a petition for certiorari and prohibition against acts of respondents assigned to Regional Office No. VI located in Cebu City. Whether Rule 67, Section 4 of the Rules of Court, concerning the venue for petitions for certiorari, prohibition, and mandamus, refers to jurisdiction over the subject matter or jurisdiction over the person/entity whose acts are being questioned.
Ruling
The Supreme Court affirmed the order of the Court of First Instance of Manila dismissing the case, holding that the venue was improperly laid. The Court ruled that the venue for certiorari and prohibition actions is determined by the location of the court having jurisdiction over the corporation, board, officer, or person whose acts are being contested, as stipulated in Rule 67, Section 4 of the Rules of Court.
Ratio Decidendi
On the venue for certiorari and prohibition: The Court clarified that Rule 67, Section 4 of the Rules of Court, which states that a petition may be filed in a Court of First Instance "having jurisdiction thereof," refers to the jurisdiction over the "corporation, board, officer or person" whose acts are being contested. This provision dictates the venue, making it dependent on where the relevant office or individual is situated. In this case, the acts complained of originated from Regional Office No. VI, located in Cebu City, and its officials, respondents Arnado and Tan. Therefore, the Court of First Instance of Cebu, not Manila, would be the proper venue. On the interpretation of Rule 67, Section 4: The Court rejected the petitioner's argument that Rule 67, Section 4, is merely a provision on jurisdiction and that venue should be governed by Rule 5, Section 1 (residence of parties). The Court emphasized that Rule 67, Section 4, is explicitly titled "Where petition filed" and clearly pertains to venue. Furthermore, the Court underscored that the rule-making power of the Supreme Court is limited to pleading, practice, and procedure, while the power to define and apportion the jurisdiction of courts rests with Congress. Allowing the Court of First Instance of Manila to entertain a case against officials in Cebu would contravene the Judiciary Act of 1948, which limits the jurisdiction of a Court of First Instance to issue such writs within its respective province or district.
Main Doctrine
The venue for actions for certiorari and prohibition, as provided in Rule 67, Section 4 of the Rules of Court, refers to the Court of First Instance having jurisdiction over the corporation, board, officer, or person whose acts are contested, and not merely the residence of the plaintiff.