Tan v. Sarmiento
REITERATIONFacts
The Antecedents: Petitioner Gregorio Tan, Jr. filed a complaint for Specific Performance of Contract and Damages with Preliminary Injunction against Gen. Godofredo Mendoza, spouses Dr. Francisco M. Garcia and Flora L. Garcia, the Director of Forestry, and the District Forester of Nueva Ecija. The complaint alleged that on October 29, 1962, the Garcia spouses granted petitioner exclusive logging rights over a parcel of land in Laur, Nueva Ecija, and authorized him to obtain a Private Woodland Registration (PWR) or Ordinary Timber License (OT). Petitioner obtained PWR No. 1925, which was renewed despite objections from the Armed Forces of the Philippines (AFP) claiming the land was part of a military reservation. Petitioner invested in logging facilities and commenced operations in September 1963, but was stopped by military orders on November 6, 1963, and his logs were impounded. The Secretary of National Defense appealed the denial of the AFP's protest against the PWR issuance. The Office of the President, on March 19, 1965, ruled that the PWR should be respected until the title or right over the land is held invalid by competent authority. However, the Commanding General refused to allow petitioner to continue logging, and the Garcia spouses also refused to comply with their obligations. Procedural History: On May 11, 1965, the Court of First Instance (CFI) of Pampanga issued a writ of preliminary injunction against the Commanding General, Director of Forestry, District Forester, and the Garcia spouses, prohibiting them from interfering with petitioner's logging operations. Subsequently, on June 22, 1965, the respondent Judge, finding merit in the motion of the Garcia spouses, issued an order lifting the writ, acknowledging the court's lack of jurisdiction to issue it for enforcement outside its territorial boundaries. After suspending the effectivity of this order, the respondent Judge, on July 2, 1965, definitively quashed the preliminary injunctive writ, holding that his court had no authority to issue an injunction to be enforced in Nueva Ecija, which was beyond its territorial jurisdiction. This order is the subject of the present petition for certiorari. The Petition: Petitioner filed a special civil action for certiorari, questioning the authority of the Court of First Instance of Pampanga to issue a writ of preliminary injunction that would be enforced outside the territorial boundaries of the province.
Issue(s)
Whether the Court of First Instance of Pampanga has the authority to issue a writ of preliminary injunction which will be enforced outside the territorial boundaries of the province. Whether the order quashing the writ of preliminary injunction issued by the respondent Judge is valid.
Ruling
The petition for certiorari is dismissed. The order of the respondent Judge quashing the writ of preliminary injunction is affirmed.
Ratio Decidendi
On the issue of territorial jurisdiction for injunctions: The Supreme Court reiterated its consistent ruling that a Court of First Instance has no jurisdiction to issue a writ of preliminary injunction to enjoin acts being performed or about to be performed outside its territorial jurisdiction. This principle was established as early as Castaño v. Lobingier (7 Phil. 91), where it was held that the power of a judge of the Court of First Instance can only be exercised within the limits of their respective districts. The Judiciary Act, as amended, specifically provides that courts and their judges have the power to issue writs of injunction, mandamus, certiorari, prohibition, quo warranto, and habeas corpus "in their respective provinces and districts." The preliminary injunction that may be granted by a court of first instance is co-extensive only with the territorial boundaries of the province or district in which the court sits. Therefore, an injunction issued by a court that purports to restrain acts outside its province is null and void for want of jurisdiction. In the present case, the writ of preliminary injunction issued by the Pampanga Court of First Instance purported to restrain acts in Nueva Ecija, which is outside its territorial jurisdiction. Consequently, the Court of First Instance of Pampanga was without authority to issue such an injunction, and its order quashing the writ was correct.
Main Doctrine
A Court of First Instance has no jurisdiction to issue a writ of preliminary injunction which is to be enforced outside its territorial jurisdiction.