G.R. No. L-30719 May 26, 1977
THE CITY OF DAVAO, ET AL., petitioners, vs. HON. WALFRIDO DE LOS ANGELES, ET AL., respondents.

FACTS

The City of Davao, through its officials, filed a petition for certiorari to annul a writ of preliminary injunction issued by respondent Judge Walfrido de los Angeles of the Court of First Instance (CFI) of Quezon City. The injunction was issued in Civil Case No. Q-13124, a complaint for specific performance and damages filed by private respondent Philippine Pipes and Merchandising Corporation against the City of Davao. The challenged order, dated July 5, 1969, commanded the Davao City Mayor and other officials to desist from including a specified quantity of pipes in a public bidding scheduled in Davao City and from contracting for the same pending litigation.
The petitioners argued that the respondent Judge acted without jurisdiction in issuing the injunction. The core contention was that a CFI judge has no authority to issue injunctive writs to control or restrain acts committed outside the territorial boundaries of his judicial district. The acts sought to be enjoined—the conduct of a public bidding and related contractual processes—were to be performed in Davao City, which is outside the territorial jurisdiction of the CFI of Rizal, Quezon City Branch.

ISSUE

Whether or not the respondent Judge of the Court of First Instance of Quezon City acted without jurisdiction in issuing a writ of preliminary injunction to restrain official acts to be performed in Davao City.

RULING

The Supreme Court granted the petition and declared the writ of preliminary injunction null and void for having been issued without jurisdiction. The legal logic is firmly rooted in the principle of territorial jurisdiction as applied to injunctive relief. The Court, citing the seminal case of Acosta v. Alvendia, reiterated that the authority of courts of first instance to issue writs of injunction is strictly limited to acts being committed or about to be committed within their respective territorial provinces and districts. This limitation is derived from Section 44 of the Judiciary Act of 1948 and Section 2 of Rule 60 of the Rules of Court.
The Court found the respondent Judge’s order a clear overreach, as it sought to control the official actions of the Davao City government, which operates entirely within a different judicial region. The attempt by the private respondent to distinguish the case by arguing that the injunction arose from an ordinary civil action, not a special civil action, was rejected. The Court emphasized that the territorial limitation applies irrespective of whether the injunction is an incident in an ordinary action for specific performance or in a special proceeding. The jurisprudence cited, including Tan, Jr. v. Sarmiento which involved an identical complaint for specific performance with injunction, uniformly supports this application. Therefore, the respondent Judge plainly exceeded his jurisdictional bounds, rendering the assailed order void.