G.R. No. L-24882. April 30, 1971. THE DIRECTOR OF FORESTRY, VALERIO O. ERGINO, AGUSTIN B. KAPUNO, FELICIANO BARRER and THE BUENO INDUSTRIAL AND DEVELOPMENT CORPORATION, petitioners, vs. JUDGE JESUS S. RUIZ, as Judge, CFI, Agusan, R.C. AQUINO TIMBER & PLYWOOD CO., INC. and RAFAEL C. AQUINO, respondents.
FACTS

Bueno Industrial and Development Corporation (BIDCOR) filed a letter-complaint with the Director of Forestry seeking the suspension and cancellation of Timber License Agreement No. 68 and an Ordinary Road Right-of-Way Permit held by R.C. Aquino Timber and Plywood Co., Inc. (TIMPLY) and its president, Rafael C. Aquino. The Director, finding the charges meritorious for investigation, created a committee to conduct hearings in Manila. TIMPLY appealed the Director’s order to the Secretary of Agriculture and Natural Resources but, during the pendency of that appeal, filed a petition for injunction with the Court of First Instance (CFI) of Agusan to halt the administrative investigation.
The CFI of Agusan, presided by Judge Jesus S. Ruiz, issued a writ of preliminary injunction restraining the Director and other forestry officials from continuing the investigation in Manila. The petitioners (the Director, other forestry officials, and BIDCOR) moved to dismiss the petition on grounds of lack of jurisdiction and non-exhaustion of administrative remedies. The lower court denied these motions and subsequent motions for reconsideration, prompting the petitioners to file the instant petition for certiorari and prohibition with the Supreme Court.

ISSUE

Whether the Court of First Instance of Agusan had jurisdiction to issue a writ of preliminary injunction restraining an administrative investigation being conducted outside its territorial jurisdiction, specifically in Manila.

RULING

The Supreme Court granted the petition, ruling that the CFI of Agusan acted without jurisdiction. The Court anchored its decision on a proper interpretation of paragraph (h), Section 44 of Republic Act No. 296 (The Judiciary Act of 1948), as amended. This provision explicitly states that courts of first instance and their judges “shall have the power to issue writs of injunction… in their respective provinces and districts.”
The legal logic is clear: this statutory language defines and limits the territorial jurisdiction of CFIs concerning injunctive relief. A CFI’s authority to issue writs of injunction is confined to acts being committed or about to be committed within the geographical boundaries of its own province or district. The administrative investigation initiated by the Director of Forestry was being conducted in Manila, which is outside the territorial jurisdiction of the CFI of Agusan. Therefore, Judge Ruiz had no legal authority to restrain proceedings occurring in Manila.
The Court rejected any argument that general provisions on court processes (like the then Section 3, Rule 135 of the Rules of Court) could expand this statutorily fixed jurisdictional limit. It emphasized that the power to define and apportion jurisdiction of courts is a legislative function under the Constitution. Since paragraph (h) of Section 44 of R.A. 296 is a legislative enactment defining jurisdiction, it prevails over rules of procedure. Consequently, the writ of preliminary injunction issued by the CFI of Agusan was null and void for want of jurisdiction. The Supreme Court made permanent its own preliminary injunction, thereby dissolving the lower court’s order and allowing the administrative investigation to proceed.