G.R. No. L-10713, March 31, 1915 (Extended Opinion: December 17, 1915)
THE MANILA RAILROAD COMPANY and THE BOARD OF PUBLIC UTILITY COMMISSIONERS, petitioners, vs. THE HONORABLE ISIDRO PAREDES, Judge of the Fourteenth Judicial District, THE TAYABAS LAND COMPANY, THE TAYABAS LAND COMPANY & LIM, LEONCIO SEÑA, and ESTEBAN CATALLA, respondents.

FACTS:
The Manila Railroad Company, under its charter, initiated expropriation proceedings on April 1, 1913, to condemn a strip of land in Tayabas for its railroad. On April 4, 1913, the court (then presided by Judge Herbert Gale) issued an order granting the Railroad Company possession of the land upon depositing the amount certified by the provincial treasurer as the average assessed value. The company deposited P8,971.72 on April 11, 1913, and was subsequently placed in possession via a writ. The respondents, including the Tayabas Land Company (which claimed ownership of most of the land), later appeared in the proceedings. On January 9, 1915, the respondents moved to increase the deposit to P1,000,000. On February 18, 1915, respondent Judge Isidro Paredes granted the motion and ordered the Railroad Company to increase its deposit to P1,000,000. The Railroad Company and the Board of Public Utility Commissioners filed an original petition for certiorari before the Supreme Court, alleging that the respondent judge acted without jurisdiction and abused his discretion in issuing the order.

ISSUE:
Whether the respondent judge had jurisdiction to issue an order increasing the amount of the deposit required from the Manila Railroad Company in the expropriation proceedings.

RULING:
No. The respondent judge acted without jurisdiction. The Supreme Court granted the writ of certiorari and declared the order null and void. The Court held that in condemnation proceedings, the court’s authority is limited to that expressly conferred by statute or necessarily incidental to its statutory duties. Under Act No. 1592 (the charter of the Manila Railroad Company), the court’s only function regarding the deposit was to fix the amount provisionally to allow the company to take immediate possession. This was done in the April 4, 1913 order, which fixed the deposit at the assessed value. Once the company complied and took possession, the court lost authority to alter the deposit. The subsequent order increasing the deposit was an attempt to exercise a power not granted by law and was therefore in excess of jurisdiction. The Court also noted that certiorari was the proper remedy, as an appeal would not provide adequate relief given the need for the railroad to proceed without delay. The order dated February 18, 1915, was declared null and void.