Cudiamat v. Torres
REITERATIONFacts
The Antecedents: The Committee on Awards for the City of Manila, composed of petitioners Manuel Cudiamat, Jose Sugay, and Jose Erestain, published an invitation to bid for a police call and signal box system. Four companies, including petitioner Marketing & Services, Inc. and respondent International Telephone & Telegraph (Philippines) Inc. (ITT), submitted bids. The committee awarded the contract to Marketing & Services, Inc., which subsequently entered into a contract with the City of Manila and opened a letter of credit. Procedural History: Respondent ITT filed a petition with the Court of First Instance (CFI) of Rizal, seeking a preliminary injunction against the award's implementation, its annulment, damages, and to be declared the winning bidder. ITT alleged that Marketing & Services, Inc. was an irresponsible bidder, that the city officials violated prohibitions against entering into transactions grossly disadvantageous to the government, and that ITT's bid was the lowest and most advantageous. The Petition: The CFI of Rizal issued a writ of preliminary injunction on October 29, 1964. The respondents (herein petitioners) moved for reconsideration, which was denied. Consequently, they filed a petition for certiorari and prohibition with the Supreme Court, seeking to annul the CFI's injunction.
Issue(s)
Whether a Court of First Instance has the jurisdiction to issue a writ of preliminary injunction that will be enforced outside the territorial boundaries of its province and district.
Ruling
The Supreme Court made permanent its writ of preliminary injunction, enjoining the implementation of the order of the Court of First Instance of Rizal. The petition for certiorari and prohibition was granted.
Ratio Decidendi
On Issue 1: The Supreme Court reasoned that the power of a court to issue an injunction is a matter of jurisdiction derived from legislative enactment, specifically the Judiciary Act. Applying Section 44(h) of the Judiciary Act, the Court noted that Courts of First Instance and their judges are empowered to issue writs of injunction only 'in their respective provinces and districts.' The Court explicitly distinguished this from Section 2, Rule 58 of the Rules of Court, stating that while the Rules prescribe the manner of exercise, they do not expand the territorial limits set by law. Citing Acosta v. Alvendia, the Court reiterated that a preliminary injunction granted by a CFI is co-extensive with the territorial boundaries of the province or district in which the court sits. Since the injunction issued by the CFI of Rizal purported to restrain acts in the City of Manila (outside the province of Rizal), the trial court exceeded its jurisdiction. Consequently, the Court made permanent the preliminary injunction it had issued on March 1, 1965, restraining the enforcement of the CFI Rizal order.
Main Doctrine
A court of first instance cannot issue a writ of preliminary injunction that is enforced outside the territorial boundaries of its province and district, as such injunction is null and void for want of jurisdiction.