Calderon v. Gomez
REITERATIONFacts
The Antecedents: Emerito S. Calderon, an independent congressional candidate, along with Congressman Manuel A. Zosa and municipal mayors, filed a petition for injunction with preliminary injunction against persons connected with public works and highway projects in Cebu. They alleged these projects, commenced before the 1965 elections, violated the Election Law and regulations, and constituted misuse of public funds, especially given the proximity to the 45-day ban on public works. Procedural History: The Court of First Instance (CFI) of Cebu, Branch VII, issued a preliminary injunction on September 16, 1965, enjoining the commencement of projects and disbursement of funds. Subsequently, Calderon filed a contempt petition against officials for violating the injunction. Meanwhile, laborers filed a petition for mandamus with preliminary mandatory injunction before the CFI of Cebu, Branch II, presided over by Judge Amador E. Gomez, seeking payment of their wages for work done from September 8 to September 16, 1965. The Petition: Calderon filed a petition for prohibition with preliminary injunction before the Supreme Court, arguing that the cognizance of the mandamus suit by Branch II constituted undue interference with the injunction issued by Branch VII, as both cases involved the disbursement of public funds for the same projects.
Issue(s)
Whether the Court of First Instance, Branch II, may take cognizance of a mandamus case seeking payment of wages for public works projects when a preliminary injunction from a co-equal court (Branch VII) has already been issued, enjoining disbursements for such projects. Whether the petition for mandamus seeking payment of wages rendered the earlier petition for injunction moot and academic.
Ruling
The Supreme Court granted the petition for prohibition and made the temporary restraining order permanent. It ruled that the CFI, Branch II, could not take cognizance of the mandamus case as it would constitute interference with the writ of preliminary injunction issued by Branch VII, a court of co-equal jurisdiction. The Court also held that the case was not moot and academic.
Ratio Decidendi
On the issue of interference between co-equal courts: The Supreme Court held that the cognizance of the mandamus suit by Branch II constituted undue interference with the preliminary injunction issued by Branch VII. The Court emphasized the settled principle that no court has the power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction. Allowing such interference would lead to confusion and hinder the administration of justice. The Court cited Onsingco, et al., vs. Tan, et al. and Mas v. Dumara-og to support this principle. The Court further explained that the basic reason for disallowing interference is to avoid confusion and ensure the unimpeded administration of justice, a fundamental objective that is disregarded when a provisional remedy from one court is used to defeat the lawful processes of a co-equal court. On the issue of mootness: The Supreme Court rejected the argument that the case had become moot and academic because the elections were over. The Court pointed out that the petition was filed to prevent the illegal and scandalous disbursement and wastage of public funds, and the issue of padded and falsified payrolls and vouchers had not been cured or rendered moot by the passing of the elections. The Court stated that the vital issue remained in dispute in Civil Case No. 241-B, and the CFI, Branch VII, should be given the opportunity to seek the truth about those documents.
Main Doctrine
A court of co-equal or coordinate jurisdiction cannot interfere with the judgments or decrees of another court of concurrent jurisdiction, as doing so would lead to confusion and hinder the administration of justice. A provisional remedy from one court cannot be used to defeat the lawful processes of a co-equal court.