G.R. No. L-13882. December 27, 1963.
VALERIANO C. BUENO, petitioner, vs. PEDRO S. PATANAO, JUDGE JESUS S. RUIZ, Municipal Judge of Butuan City, JUDGE MONTANO A. ORTIZ, Court of First Instance of Agusan, PROVINCIAL SHERIFF, AGUSAN, respondents.

FACTS

Petitioner Valeriano C. Bueno and respondent Pedro S. Patanao are holders of adjacent forest concession licenses. Patanao filed a complaint for injunction and damages with the Court of First Instance (CFI) of Agusan, alleging that Bueno and his men, armed with firearms, had illegally entered his concession area, cut and hauled valuable logs, and intended to continue denuding the area. He sought a preliminary injunction. The presiding CFI judge, being absent, issued an order authorizing the Municipal Judge of Butuan City “to receive the evidence of the movant for the purpose of deciding whether the injunction should issue or not.” The Municipal Judge, after hearing, granted the writ of preliminary injunction. Subsequently, an alias writ was issued, leading to the sheriff’s confiscation and delivery of logs from Bueno to Patanao.
Bueno filed a motion for reconsideration, which the CFI judge denied, ruling that the Municipal Judge had jurisdiction under the Judiciary Act. Bueno then filed this petition for certiorari and prohibition, arguing that the Municipal Judge acted in excess of jurisdiction and with grave abuse of discretion. He contended that the dispute involved a boundary conflict between concessionaires, which fell under the primary jurisdiction of the Bureau of Forestry, and that Patanao had not exhausted administrative remedies.

ISSUE

The primary issue is whether the Municipal Judge had jurisdiction to hear and grant the application for a preliminary injunction. A corollary issue is whether the CFI itself had jurisdiction over the main action, given the claim that the dispute involved an administrative matter concerning public forest concessions.

RULING

The Supreme Court dismissed the petition. On the first issue, the Court held that the Municipal Judge acted within his jurisdiction. Section 88 of the Judiciary Act grants municipal judges in chartered cities interlocutory jurisdiction to hear motions for preliminary injunctions, co-equal with CFI judges. The CFI judge’s order, though phrased as authorizing the Municipal Judge merely “to receive the evidence,” did not restrict this statutory grant of power. The Municipal Judge was therefore empowered to receive evidence from both parties and to decide on the injunction application.
On the more substantive issue, the Court ruled that the CFI validly acquired jurisdiction over the main action for injunction and damages. The case was not merely a boundary dispute over public forest lands requiring prior administrative resolution by the Bureau of Forestry. Patanao’s complaint alleged tortious acts—illegal entry, cutting of timber, and intimidation by armed men—which constituted a cause of action independent of the license boundaries. Furthermore, Bueno’s defense invoked a contractual agreement between the parties regarding the logging operations. Following the precedent in Espinosa v. Makalintal, the Court held that controversies arising from civil, tortious, or contractual relations between parties are judicial in nature. Questions involving alleged deprivation of possession, damages from tortious acts, and the interpretation of contracts are within the exclusive competence of regular courts, not administrative agencies. The administrative jurisdiction of the Bureau of Forestry is limited to executive functions like granting licenses and deciding conflicting applications, not adjudicating tort or contract claims. Therefore, the CFI properly took cognizance of the case, and the issuance of the preliminary injunction was a valid exercise of judicial discretion. The preliminary injunction issued by the Supreme Court was dissolved.