Dagupan Electric Corporation v. Honorable Ernani Cruz Pano
REITERATIONFacts
The Antecedents: MC Adore Finance and Investment, Inc. (MC Adore), owner of a hotel in Dagupan City, was a customer of Dagupan Electric Corporation (DECORP), which supplies electricity in Dagupan and surrounding areas, with its principal office in Quezon City. Due to MC Adore's failure to pay its September and October 1978 bills, DECORP served a notice of disconnection and subsequently disconnected electrical services on November 27, 1978. Procedural History: On December 6, 1978, MC Adore filed a complaint for damages with a writ of preliminary mandatory injunction against DECORP and its officers in the Court of First Instance (CFI) of Rizal, Branch XVIII, Quezon City. The CFI judge issued an ex parte order for preliminary mandatory injunction, commanding DECORP to immediately restore electrical services. Subsequently, MC Adore filed a petition to declare DECORP and its officers in contempt for non-compliance. On December 8, 1978, the CFI judge issued an order for the arrest and confinement of DECORP's officers if the mandatory injunction was not complied with by midnight of December 8, 1978. DECORP filed a motion for reconsideration of these orders, arguing lack of jurisdiction, excess of jurisdiction, or grave abuse of discretion. On December 19, 1978, the CFI judge denied the motion for reconsideration and ordered the enforcement of the preliminary mandatory injunction. The Petition: DECORP and its officers filed an original special civil action for certiorari and prohibition with the Supreme Court, seeking to annul the proceedings in the CFI case and prohibit the respondent judge from proceeding further, alleging lack of jurisdiction and grave abuse of discretion.
Issue(s)
Whether the Court of First Instance of Rizal, Branch XVIII, Quezon City, has jurisdiction over Civil Case No. Q-26502. Whether the respondent judge acted with grave abuse of discretion in issuing the writ of preliminary mandatory injunction.
Ruling
The petition for certiorari and prohibition is dismissed. The Court of First Instance of Rizal, Branch XVIII, Quezon City, has jurisdiction over the case. The respondent judge did not commit a grave abuse of discretion in issuing the writ of preliminary mandatory injunction. The MC Adore Finance and Investment, Inc. is directed to pay the monthly bills as presented by DECORP from June 1979. If MC Adore fails to do so within ten (10) days from notice, DECORP may disconnect the electric power from the hotel. The correct amounts due prior to June 1979 shall be resolved by the respondent judge after hearing the parties. The motions for contempt against Modesto Sabeniano and Jose T. Apigo are denied for lack of merit.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the Court of First Instance of Rizal at Quezon City has jurisdiction over the case. The Court reasoned that DECORP's principal office and decision-making authority are located in Quezon City, and the disconnection order originated from this location. The employees in Dagupan City merely carried out orders issued by the Quezon City head office. Therefore, the acts sought to be restrained were considered to be committed in Quezon City, establishing territorial jurisdiction. The Court cited that both parties are residents of Quezon City as they have their principal offices there, and the exercise of DECORP's will had its origin in Quezon City, causing potential irreparable prejudice to MC Adore's property rights. On the issue of grave abuse of discretion in issuing the preliminary mandatory injunction: The Supreme Court ruled that the respondent judge did not commit a grave abuse of discretion. The Court found that the judge conducted hearings and gave the parties full opportunity to present their evidence before issuing the orders. The judge's order of December 19, 1978, detailed the proceedings, including the dispute over billing changes, the suspension of the writ pending a full hearing, and the evidence presented. The Court noted that the operation of MC Adore's hotel, valued at P75 million with significant government equity, would be prejudiced if paralyzed due to the dispute. The judge's order to reinstate the mandatory injunction, while requiring MC Adore to deposit a sum and post an additional bond, demonstrated a balanced approach to protect both parties' interests and public interest pending a full resolution of the dispute.
Main Doctrine
A court has jurisdiction over a case if the acts sought to be restrained originated from its territorial jurisdiction, even if the physical act of disconnection occurred elsewhere, provided the corporation's principal office and decision-making authority are located within that jurisdiction. The issuance of a preliminary mandatory injunction is not a grave abuse of discretion when it aims to prevent irreparable prejudice to property rights and public interest, especially when hearings have been conducted and parties given the opportunity to present evidence.