Davao v. De los Angeles
REITERATIONFacts
The Antecedents: The City of Davao, through its Mayor and City Council members, filed a certiorari proceeding against the Judge of the Court of First Instance of Quezon City and Philippine Pipes and Merchandising Corporation. The City of Davao sought to annul a writ of preliminary injunction issued by the respondent Judge. Procedural History: The respondent Judge issued a writ of preliminary injunction on July 5, 1969, in Civil Case No. Q-13124, where Philippine Pipes and Merchandising Corporation was the plaintiff and the City of Davao was a defendant. The injunction ordered the City of Davao, its Mayor, and other officials to desist from including 17,963 lineal meters of 18" pipes, covered by three (3) Letter Orders, in a public bidding scheduled for July 10, 1969, and from contracting for the same, pending the final termination of the litigation. The Petition: The City of Davao contended that the respondent Judge acted without jurisdiction in issuing the writ of preliminary injunction.
Issue(s)
Whether the respondent Judge acted without jurisdiction in issuing the writ of preliminary injunction. Whether the ruling in Acosta v. Alvendia, which limits the territorial jurisdiction of Courts of First Instance to issue injunctions, is applicable to ordinary civil suits.
Ruling
The order of preliminary injunction of July 5, 1969, issued by the then respondent Judge Walfrido de los Angeles is declared null and void and of no force and effect for having been issued without jurisdiction. Costs against private respondent.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the respondent Judge acted without jurisdiction in issuing the writ of preliminary injunction. The Court reiterated the principle established in Acosta v. Alvendia and subsequent cases, stating that the authority of courts of first instance to control or restrain acts by injunction is limited to acts committed or to be committed within the territorial boundaries of their respective provinces and districts. The issuance of an injunction that extends beyond these territorial limits constitutes a grave abuse of discretion amounting to lack of jurisdiction. On the applicability of Acosta v. Alvendia: The Supreme Court found the private respondent's attempt to distinguish the applicability of the Acosta v. Alvendia ruling futile. The Court clarified that the principle enunciated in Acosta v. Alvendia and its subsequent applications are not limited to special civil actions but also apply to ordinary civil suits. The Court cited several cases, including Hacbang v. The Leyte Autobus Co., Inc. and Cudiamat v. Torres, which were ordinary civil cases where the principle was applied. Furthermore, the most recent case of Tan, Jr. v. Sarmiento involved a complaint for specific performance of a contract and damages with preliminary injunction, similar to the case pending before the respondent Judge, further negating the distinction attempted by the private respondent. Therefore, the respondent Judge's order was issued without jurisdiction.
Main Doctrine
A Court of First Instance acts without jurisdiction in issuing a writ of preliminary injunction to control or restrain acts committed or to be committed outside the territorial boundaries of its province or district.