Hacbang v. Leyte Autobus
REITERATIONFacts
The Antecedents: Petitioners, Provincial Sheriff and Deputy Provincial Sheriff of Leyte, and the Bustillos, sought to set aside orders of the Court of First Instance (CFI) of Cebu and to enjoin it from hearing a case. A decision in Civil Case No. 2045 of the CFI of Leyte ordered Leyte Autobus Co., Inc. (LAC) to pay P6,352.00 to Otilla Bustillo and her minor children. This decision was affirmed by the Court of Appeals. A writ of execution was issued, and petitioners levied upon a passenger bus. LAC filed a third-party claim, asserting ownership of the bus and alleging it was a different entity from the defendant in Civil Case No. 2045. The CFI of Leyte denied the third-party claim, ruling that LAC was the same defendant and judgment debtor. Procedural History: On the scheduled date of the bus sale, LAC filed Civil Case No. R-6542 in the CFI of Cebu against the Leyte sheriffs, seeking an injunction to stop the sale and a declaration of ownership. The CFI of Cebu issued a preliminary injunction. The Leyte sheriffs moved to dismiss, arguing the Cebu court lacked authority to restrain the execution of a Leyte judgment and that the complaint stated no cause of action. The motion was denied. The sheriffs filed an answer, reiterating their arguments and asserting they acted in compliance with the Leyte court's orders. The Petition: Petitioners (Leyte sheriffs and Bustillos) filed a petition for certiorari and prohibition with this Court, alleging the CFI of Cebu acted without or in excess of jurisdiction in entertaining the case and issuing the injunction. They prayed for the annulment of the Cebu court's orders and injunction, and for a perpetual prohibition against the Cebu judge hearing the case.
Issue(s)
Whether the Court of First Instance of Cebu has the authority to restrain the execution of a judgment rendered by the Court of First Instance of Leyte. Whether the Court of First Instance of Cebu has the authority to issue an injunction restraining acts outside its territorial jurisdiction.
Ruling
The writ of preliminary injunction issued by the respondent Judge in Civil Case No. R-6542 of Cebu is set aside and annulled. The preliminary injunction issued by the Supreme Court on January 12, 1961, is made permanent. Costs against respondent Company.
Ratio Decidendi
On the issue of whether the CFI of Cebu has the authority to restrain the execution of a judgment rendered by the CFI of Leyte: The Supreme Court held that the respondent Judge acted without or in excess of jurisdiction. Property levied upon under a writ of execution is considered in custodia legis, under the sole control of the court that issued the writ. No court, except one with supervisory or superior jurisdiction, has the right to interfere with this possession. 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 having equal power to grant the relief sought. This principle is essential to avoid conflicts of power between courts of coordinate jurisdiction and to prevent confusion in the administration of justice. Allowing coordinate courts to interfere with each other's judgments by injunctions would hinder the proper administration of justice. The Court cited National Power Corporation vs. Hon. Jesus de Veyra and Cabigao vs. Del Rosario in support of this principle. On the issue of whether the CFI of Cebu has the authority to issue an injunction restraining acts outside its territorial jurisdiction: The Supreme Court affirmed that the jurisdiction of courts of first instance to control or restrain acts by injunction is limited to acts committed or about to be committed within their territorial boundaries. The Court cited Acosta vs. Alvendia and Central Bank vs. Cajigal to support this ruling. Therefore, the CFI of Cebu could not restrain the execution of a judgment in Leyte, as the acts to be restrained were occurring outside its territorial limits. The Court clarified that this does not preclude LAC from vindicating its claim of ownership before the proper court, as reserved by Section 15 of Rule 39 of the Rules of Court, but this is separate from restraining the execution of the Leyte court's judgment.
Main Doctrine
A court of coordinate jurisdiction cannot interfere by injunction with the judgments or decrees of another court of concurrent jurisdiction having equal power to grant the relief sought. Furthermore, the territorial jurisdiction of a court in issuing injunctions is limited to acts within its territorial boundaries.