G.R. No. L-20920 December 18, 1968
Restituto M. Sibal, petitioner, vs. Gregorio T. Lantin, in his capacity as Presiding Judge of the Court of First Instance of Manila, Branch VII, The Spouses Lorenzo & Inocencia Valdez, et al., respondents.

FACTS

On September 5, 1955, Valleson, Inc., represented by Lorenzo Valdez, executed a “Contract of Transfer of Management” with Restituto Sibal, transferring to Sibal the wholesale and retail business activities of Valleson until September 4, 1962. On the same date, Sibal and Mariano Guison executed a contract of lease (first contract) for the Angela Building, occupied by Valleson, for a term ending September 1962, “to be renewed only upon agreement of both parties.” On March 1, 1962, Guison and Sibal executed a second contract of lease for the same building for ten years beginning September 2, 1962. Subsequently, Sibal notified the former concessionaires/sublessees of Valleson to vacate, threatening ejectment proceedings.
On September 4, 1962, Valleson filed Civil Case No. 51476 against Guison and Sibal in the Court of First Instance (CFI), presided by Judge Gregorio T. Lantin, alleging Sibal acted as Valleson’s representative in the first lease and seeking a declaration of Valleson’s right to renew the lease. A writ of preliminary injunction was issued restraining Guison and Sibal from interfering with Valleson’s possession.
Between November and December 1962, Sibal filed six unlawful detainer cases (ejectment cases) in the Manila Municipal Court against the sublessees (respondents herein). The municipal court, presided by Judge W.L. Cornejo, denied the sublessees’ motions to dismiss based on the pendency of CFI Case No. 51476 and set the cases for hearing.
On January 22, 1963, the sublessees filed CFI Case No. 52866 against Judge Cornejo and Sibal, seeking to restrain further proceedings in the ejectment cases, alleging Judge Cornejo acted without jurisdiction or with grave abuse of discretion due to the pendency of CFI Case No. 51476. On January 31, 1963, Judge Lantin authorized a writ of preliminary injunction against Judge Cornejo upon filing a bond. Sibal then filed the present certiorari/prohibition case to annul Judge Lantin’s order.

ISSUE

Whether or not Judge Gregorio T. Lantin acted with grave abuse of discretion amounting to excess of jurisdiction in issuing the order of January 31, 1963, in CFI Case No. 52866, authorizing a writ of preliminary injunction to restrain the municipal court from proceeding with the ejectment cases.

RULING

Yes, Judge Lantin acted with grave abuse of discretion amounting to excess of jurisdiction. The Supreme Court granted the writ, declaring the order and the writ of preliminary injunction null and void ab initio.
The prerequisites for a preliminary injunction under Rule 58, Section 3 of the Rules of Court include that the plaintiff is entitled to the relief demanded. The relief sought in CFI Case No. 52866 was a writ of certiorari and/or prohibition against Judge Cornejo, which requires a showing that he acted without or in excess of jurisdiction. The ejectment cases were within the exclusive original jurisdiction of the municipal court under Section 88 of Republic Act No. 296 , as amended; thus, Judge Cornejo had the authority and duty to hear and decide them.
The sublessees’ claim that the issues in the ejectment cases were raised in the earlier-filed CFI Case No. 51476, constituting a prejudicial question, was untenable. The parties in the two sets of cases were different: CFI Case No. 51476 involved Valleson vs. Sibal and Guison, while the ejectment cases involved Sibal vs. the sublessees, with Valleson not a party. The issues were also distinct: CFI Case No. 51476 concerned the right to renew the lease of the Angela Building, while the ejectment cases involved the right to possess specific premises based on sublease agreements. The first lease contract explicitly stated renewal was only “upon agreement of both parties,” and the record showed no such agreement between Valleson and Guison, while Guison confirmed the second lease was with Sibal personally. Therefore, Judge Cornejo committed no abuse of discretion in proceeding with the ejectment cases, and consequently, the sublessees were not entitled to the writ sought in CFI Case No. 52866. Judge Lantin’s order restraining a co-equal court from exercising its exclusive jurisdiction constituted a grave abuse of discretion.