GR L 6448; (February, 1954) (Digest)
G.R. No. L-6448 February 25, 1954
PHILIPPINES INTERNATIONAL FAIR, INC., LUIS MONTILLA, FEDERICO MANGAHAS and JUAN COLLAS, petitioners, vs. HON. FIDEL IBAÑEZ, as Judge of the Court of First Instance of Manila, PONCIANO B. JACINTO and SIMEON G. DEL ROSARIO, respondents.
FACTS
The Philippines International Fair, Inc. announced an essay contest titled “500 Years of Philippine Progress” with specific rules, including that the essay must be in formal type, historically correct, and contain not less than 800 nor more than 1,000 words. The contest involved preliminary rounds in ten newspapers, with each first-prize winner becoming eligible for a Grand Prize of P500. A board of judges appointed by the Director General adjudged Enrique Fernandez Lumba as the winner. Ponciano B. Jacinto filed a complaint in the Court of First Instance of Manila (Civil Case No. 18255) questioning the validity of the award, and the court issued a preliminary injunction. The defendants (petitioners herein) answered, asserting that the court had no jurisdiction over the subject matter and that the complaint stated no cause of action, invoking the rule in Felipe v. Leuterio. The respondent court ruled it had jurisdiction and denied a motion for reconsideration. The petitioners then filed this petition for certiorari and prohibition, arguing the respondent court acted without jurisdiction and that there was no plain, speedy, and adequate remedy.
ISSUE
Whether the respondent Court of First Instance of Manila has jurisdiction over Civil Case No. 18255, which challenges the award made by the board of judges in the essay contest.
RULING
The Supreme Court denied the petition for certiorari and prohibition and discharged the preliminary injunction. The Court held that while an order denying a motion to dismiss on jurisdictional grounds is interlocutory and generally not appealable, a higher court may issue extraordinary writs if it is clear the trial court lacks jurisdiction. However, the facts alleged in the complaint, if proven, constitute an actionable wrong or tortious act committed by the board of judges. In the absence of a clear showing that the respondent court lacks jurisdiction over such a case, the rule against appealing interlocutory orders must be adhered to, and extraordinary remedies cannot be used to review such an order. The Court found no basis to conclude the respondent court lacked jurisdiction.