Herrera v. Barretto
REITERATIONFacts
The Antecedents: Constancio Joaquin sought a license to operate a cockpit in Caloocan. Upon refusal by Municipal President Godofredo B. Herrera, Joaquin filed an action for mandamus to compel the issuance of the license. Joaquin also requested a mandatory injunction to allow him to operate the cockpit provisionally during the pendency of the action. Procedural History: The Court of First Instance of Rizal, ex parte and without notice to Herrera, issued the mandatory injunction based on Joaquin's complaint and annexed exhibits. The Petition: Herrera filed a petition for a writ of certiorari with the Supreme Court, alleging that the Court of First Instance and Judge Alberto Barretto exceeded their jurisdiction in issuing the mandatory injunction on several grounds, including that the municipal council, not the municipal president, had the authority to issue cockpit licenses, that the injunction was issued ex parte without notice, that the license had been annulled, and that another action was pending which would be rendered inefficacious by the injunction.
Issue(s)
Whether the Court of First Instance exceeded its jurisdiction in issuing a mandatory injunction in a Mandamus proceeding, thereby making its action reviewable via Certiorari.
Ruling
The petition for a writ of certiorari is denied, and the proceeding is dismissed.
Ratio Decidendi
On Issue 1: The Supreme Court emphasized that jurisdiction is the power to hear and determine a cause, which is distinct from the exercise of that jurisdiction. Applying the principles from Chase v. Christianson, the Court noted that once jurisdiction over the person and subject matter is conceded, the decision of all other questions is merely an exercise of that power. The CFI had general jurisdiction over Mandamus actions and was therefore authorized to resolve every question arising therein, including the propriety of a mandatory injunction. Even if the court's decision was 'wrongfully' issued or based on 'insufficient grounds,' such errors constitute errors of judgment corrigible by appeal, not a lack of jurisdiction. The Court clarified that the office of the writ of Certiorari is reduced solely to the correction of jurisdictional defects and cannot be used as a substitute for a writ of error. Furthermore, the Court noted that Herrera should have first moved for the dissolution of the injunction in the lower court before seeking extraordinary relief, emphasizing that questions within the CFI's competence should not be summarily removed from their consideration.
Main Doctrine
A writ of certiorari will not be issued to correct errors in the proceedings or to cure erroneous conclusions of law or fact if the court acted with jurisdiction. The issuance of a mandatory injunction, even if irregular or erroneous, is within the court's jurisdiction and not reviewable by certiorari if the court had jurisdiction over the subject matter and the person.