Mendoza v. Cruz
REITERATIONFacts
The Antecedents: The underlying dispute arose from a public bidding for the supply of school equipment in Pangasinan. Petitioner Gonzalo B. Mendoza, doing business as Gonzalo B. Mendoza & Sons, submitted the lower bid and was awarded the contract by Division Superintendent of Schools Conrado G. Genilo. Mendoza began delivering the equipment, with deliveries nearly complete by the end of October 1966. Procedural History: On November 2, 1966, respondent Restituto H. Samson, Jr., doing business as Glo-Zen Suppliers, filed a petition for injunction with preliminary writ of injunction in the Court of First Instance of Rizal, Caloocan City (Civil Case No. C-878). Samson sought to prevent Mendoza from further deliveries and Genilo from making payments, alleging the bidding was fraudulent. The respondent Judge issued an ex parte writ of preliminary injunction upon Samson's filing of a P2,000.00 bond. The petitioners' motion to lift the restraining order was denied. Subsequently, the petitioners filed the instant petition for certiorari with preliminary injunction to annul the order, arguing the respondent Judge lacked jurisdiction as the acts were to be committed outside his territorial jurisdiction. The respondent Judge's order was later mooted when Samson sought dismissal of Civil Case No. C-878. The Petition: The petitioners filed a petition for certiorari, seeking to annul the order of the respondent Judge of the Court of First Instance of Caloocan City, alleging it was issued without jurisdiction. They argued that the respondent Judge exceeded his authority by issuing a writ of preliminary injunction to restrain acts occurring outside his territorial jurisdiction. The petitioners also sought damages and attorney's fees due to the alleged reckless filing of the injunction case. However, the Court found the petition moot and academic due to Samson's subsequent motion to dismiss the original case and noted that claims for damages should be pursued through the injunction bond or in a separate case already filed in the proper jurisdiction.
Issue(s)
Whether the respondent Judge had jurisdiction to issue the writ of preliminary injunction. Whether the petition is moot and academic. Whether damages can be awarded in the petition.
Ruling
The petition is dismissed. The writ of preliminary injunction previously issued is lifted. Costs are against the respondent Restituto H. Samson, Jr.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the respondent Judge had no jurisdiction to issue the writ of preliminary injunction. The Court reiterated the settled rule 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. In this case, the acts sought to be restrained, namely the delivery of school equipment and the payment therefor, were to be performed in Pangasinan, which is outside the territorial jurisdiction of the Court of First Instance of Rizal, Caloocan City. Therefore, the respondent Judge exceeded his jurisdiction in issuing the restraining order. On the issue of mootness: The Supreme Court found the petition to be moot and academic. This was based on the manifestation by the respondents that the plaintiff in the principal case, Restituto H. Samson, Jr., had filed a motion to dismiss Civil Case No. C-878. The dismissal of the principal case would necessarily lead to the quashal of the writ of preliminary injunction, rendering the petition to quash the writ moot and academic. The Court noted that Samson had intimated an intention to refile the case in the proper court. On the issue of damages: The Supreme Court ruled that the application for damages contained in the petitioners' Reply could not be entertained in the present petition. The Court explained that an injunction bond serves as security for damages that may be suffered if the injunction is found to have been improperly granted. The Rules of Court prescribe a specific procedure for claiming damages against an injunction bond, which requires the claim to be presented in the principal action and included in the final judgment. The application must be filed before the trial or before the judgment becomes executory, with due notice to the plaintiff and his sureties. Furthermore, the Court noted that the petitioners had specifically asked for damages arising from the issuance of the writ in another pending case (Special Civil Action No. 14589) before the Court of First Instance of Pangasinan, which is the proper venue for such claims.
Main Doctrine
A court's authority to issue a writ of injunction is limited to acts committed or about to be committed within its territorial jurisdiction. A petition seeking to quash a writ of injunction becomes moot and academic if the plaintiff in the principal case seeks dismissal of the case and consequent quashal of the writ.