De Jesus v. Garcia
REITERATIONFacts
The Antecedents: Petitioners Pablo, Engracia, and Manuela de Jesus, along with respondent Maxima de Jesus and seven others, were co-owners of six parcels of land in Sampaloc, Manila. Maxima de Jesus acted as the administratrix and attorney-in-fact, receiving a 10% commission on rentals collected. The property was leased to The Shell Company of the Philippines, Ltd. (Shell). The lease was renewed, increasing monthly rentals from P850.00 to P3,500.00. Shell issued a check for P3,500.00 payable to Maxima de Jesus, who then distributed the shares to the co-owners after deducting her commission. In October 1966, petitioners allegedly instructed Shell not to pay Maxima de Jesus directly but to pay their shares directly to them, thereby attempting to deprive her of her 10% compensation. Procedural History: Maxima de Jesus, assisted by her husband Salvador Barrios, filed a complaint against petitioners and Shell in the City Court of Manila. She sought a writ of preliminary injunction to compel Shell to continue paying rentals to her and a final injunction, along with a judgment ordering petitioners to pay her 10% compensation. The City Court issued an ex-parte writ of preliminary injunction. Petitioners filed a motion to dismiss and dissolve the injunction, arguing lack of jurisdiction over the subject matter and the power to issue injunctions. The City Court denied this motion, prompting petitioners to file an original action for certiorari and prohibition with the Supreme Court. The Petition: Petitioners sought to annul the proceedings in the City Court, arguing that the City Court lacked jurisdiction over the subject matter (specific performance and injunction) and the power to issue the writ of preliminary injunction.
Issue(s)
Whether the City Court of Manila has jurisdiction over the subject matter of the complaint, which involves specific performance of a contract and injunction. Whether the City Court of Manila has the power to issue a writ of preliminary injunction in the given case.
Ruling
The petition for certiorari and prohibition is granted. The writ of preliminary injunction issued by the respondent City Court is declared final, and the respondent court is directed to dismiss Civil Case No. 153460.
Ratio Decidendi
On the issue of jurisdiction over the subject matter: The Supreme Court held that the City Court of Manila has no jurisdiction over the subject matter of the complaint. The complaint, when taken as a whole, primarily seeks specific performance of a contract, compelling Shell to continue the previous mode of payment and ordering the dissenting co-owners to recognize Maxima de Jesus's right to her 10% compensation as administratrix. Specific performance is an action "not capable of pecuniary estimation," which falls under the exclusive jurisdiction of the Court of First Instance, not the City Court. The Court distinguished this from cases where the primary relief sought is a sum of money within the City Court's limited jurisdiction, emphasizing that payment of monetary amounts in specific performance cases is merely a consequence of the primary relief sought. The Court also noted that splitting the cause of action by filing successive suits for monthly rentals would be contrary to the principle against multiplicity of suits, as the breach alleged was total and indivisible. On the issue of the power to issue a writ of preliminary injunction: The Supreme Court ruled that the City Court is without jurisdiction to hear and determine a case for final injunction. Such authority is expressly granted by statute to Courts of First Instance. Furthermore, the power of city courts to issue preliminary injunctions is statutorily limited. Historically, this power was initially absent, then granted only for forcible entry cases, and later extended to municipal courts in provincial capitals only in the absence of a district judge, and solely in specific circumstances. The Court clarified that Section 2 of Rule 58, which states that a preliminary injunction may be granted by the judge of "any court in which the action is pending," must be read in context. Since the City Court lacked jurisdiction over the subject matter, it was powerless to grant an ancillary remedy like a preliminary injunction. The Court emphasized that absent an explicit statutory grant of jurisdiction, a city court cannot assume such power, and parties seeking injunctive relief should resort to the Court of First Instance.
Main Doctrine
City courts lack jurisdiction over actions for specific performance, as such actions are not capable of pecuniary estimation and fall under the exclusive jurisdiction of courts of first instance. Furthermore, city courts are generally without power to issue final injunctions, with such authority expressly granted to courts of first instance. The power to issue preliminary injunctions for city courts is statutorily limited, primarily to cases involving forcible entry.