GR L 15763; (December,1961) (Digest)
G.R. No. L-15763 December 22, 1961
NATIONAL POWER CORPORATION, petitioner, vs. HON. JESUS DE VEYRA, as Judge of the Court of First Instance of Baguio City and the CITY OF BAGUIO, respondents.
FACTS
The Court of First Instance (CFI) of Manila rendered a final decision ordering the City of Baguio to pay the National Power Corporation (NPC) a sum of money. Upon NPC’s motion, the Manila court issued a writ of execution. The Sheriff of Baguio City, in compliance, garnished cash deposits of Baguio City held at the Philippine National Bank.
Subsequently, Baguio City filed a complaint (Civil Case No. 866) in the CFI of Baguio against NPC, the Bank, and the Sheriff. The complaint sought to declare the garnishment illegal and to permanently restrain its enforcement, alleging the funds were exempt from execution. On the same day, the Baguio CFI issued a preliminary mandatory injunction ordering the restoration of the garnished funds. NPC’s motions for reconsideration and dismissal, citing lack of jurisdiction, were denied, prompting this certiorari petition.
ISSUE
Whether the CFI of Baguio had jurisdiction to issue an injunction and entertain a suit impugning the legality of a garnishment levied by the Sheriff under a writ of execution issued by the CFI of Manila.
RULING
The Supreme Court ruled that the CFI of Baguio acted without jurisdiction. The legal principle is that property validly levied upon under a writ of execution is brought into the custody of the law (in custodia legis) and falls under the exclusive jurisdiction of the court that issued the writ. The garnishment by the Manila CFI’s sheriff created a lien and placed the bank deposits under the sole control and jurisdiction of the Manila court.
A court of coordinate jurisdiction, like the CFI of Baguio, cannot interfere by injunction with the judgment or processes of another court of equal rank. To allow such interference would create conflicts of authority and hinder the administration of justice. The proper remedy for Baguio City, if it believed the levy was illegal due to exemption, was to seek relief directly from the Manila court, which had supervisory authority over the execution of its own judgment. Consequently, the Supreme Court set aside the preliminary mandatory injunction and enjoined further proceedings in Civil Case No. 866 before the Baguio court.