G.R. No. L-17907; May 30, 1963
JOAQUIN HACBANG and BASTRO BARDELOSA, (in their capacities as Provincial Sheriff Ex-Oficio and Deputy Provincial Sheriff, Province of Leyte, respectively) and OTILLA BUSTILLO, and her minor children ERLINDA BUSTILLO and ORLANDO BUSTILLO, the latter two represented by the former as their guardian ad-litem, petitioners, vs. THE LEYTE AUTOBUS COMPANY, INC., and HONORABLE CLEMENTINO V. DIEZ, in his capacity as Presiding Judge of the Court of First Instance of Cebu, 14th Judicial District, Branch I, respondents.

FACTS

The Court of First Instance (CFI) of Leyte rendered a judgment against Leyte Autobus Co., Inc., ordering it to pay damages to the Bustillos. After the judgment became final, a writ of execution was issued. The provincial sheriff levied upon a passenger bus registered under the name “Leyte Autobus Co., Inc.” The respondent company filed a third-party claim in the Leyte court, asserting it was a different corporate entity from the judgment debtor and owned the bus. The Leyte court denied this claim, ruling the respondent company was the same judgment debtor, and ordered the bus’s sale.
On the scheduled auction date, the respondent company filed a separate action for injunction and declaration of ownership (Civil Case No. R-6542) in the CFI of Cebu against the sheriffs. The Cebu court, presided by Judge Diez, issued a writ of preliminary injunction restraining the sheriffs from proceeding with the sale. The sheriffs and the Bustillos moved to dismiss the Cebu case, arguing the Cebu court had no authority to interfere with the execution of a judgment by the Leyte court. This motion was denied.

ISSUE

Whether the Court of First Instance of Cebu had jurisdiction to issue a writ of preliminary injunction restraining the execution of a final judgment rendered by the Court of First Instance of Leyte.

RULING

The Supreme Court ruled that the CFI of Cebu acted without jurisdiction in issuing the injunction. The legal logic is anchored on the fundamental principle that a court of coordinate or concurrent jurisdiction cannot interfere by injunction with the judgments or orders of another court of equal rank. The power to control and enforce its own judgments is inherent in the court that rendered the decision. Allowing the Cebu court to enjoin the execution of the Leyte court’s final judgment would undermine judicial stability and the orderly administration of justice, as it would permit the re-litigation of matters already settled by a court of competent jurisdiction.
Furthermore, the territorial jurisdiction of a court of first instance to issue injunctive relief is limited to acts committed or about to be committed within its own province or district. The sheriffs were acting in Leyte pursuant to a lawful writ from the Leyte court; the Cebu court therefore had no authority to restrain acts performed outside its territorial boundaries. The Supreme Court clarified that the respondent company’s remedy, if it genuinely claimed ownership distinct from the judgment debtor, was to pursue its third-party claim in the execution proceedings in Leyte, as provided under the Rules of Court, or to file a separate action for damages after the execution sale, without seeking to enjoin the sale itself. The writ of preliminary injunction issued by the Cebu court was annulled and made permanently ineffective.