G.R. No. L-17109; June 30, 1961
SAMAR MINING CO., INC., petitioner-appellant, vs. FRANCISCO P. ARNADO, POMPEYO V. TAN and RUFINO ABUYEN, respondents-appellees.

FACTS

Petitioner Samar Mining Co., Inc., a corporation established in Manila, sought to annul proceedings before the Workmen’s Compensation Commission. Respondent Rufino Abuyen filed a compensation claim for an illness contracted during his employment. The claim was docketed and assigned for hearing in Catbalogan, Samar, by respondent Labor Attorney Pompeyo V. Tan of Department of Labor Regional Office No. VI, located in Cebu City. Petitioner challenged Tan’s authority to conduct the hearing, arguing such power was vested in the Regional Office itself. Despite petitioner’s non-appearance, Tan proceeded, heard evidence, and rendered a decision awarding compensation to Abuyen.
Petitioner’s motion for reconsideration, filed with the Regional Office, was denied. Consequently, petitioner filed an action for certiorari and prohibition with the Court of First Instance (CFI) of Manila against respondents Arnado (Regional Administrator), Tan, and Abuyen. Petitioner alleged that Tan acted without jurisdiction and with grave abuse of discretion. The Manila CFI issued a preliminary injunction but later dismissed the case upon respondents’ motion, holding that venue was improperly laid in Manila.

ISSUE

Whether the Court of First Instance of Manila was the proper venue for the special civil actions of certiorari and prohibition instituted by the petitioner.

RULING

The Supreme Court affirmed the dismissal, ruling that venue was improperly laid in Manila. The Court held that the governing provision is Rule 67, Section 4 of the Rules of Court, which states that a petition for certiorari or prohibition against an officer or person must be filed in a Court of First Instance “having jurisdiction thereof.” This provision pertains to venue, making it coterminous with the court’s jurisdiction over the person of the respondent officer or the office whose acts are contested.
The legal logic is clear: the jurisdiction referred to in Rule 67, Section 4 is the court’s authority over the corporation, board, officer, or person whose acts are challenged, not merely jurisdiction over the subject matter. Since the contested proceedings were undertaken by and under the authority of Regional Office No. VI located in Cebu City, and respondents Arnado and Tan were agents of that office, the Court of First Instance with territorial jurisdiction over Cebu City was the proper venue. The Court rejected petitioner’s theory that general venue rules (Rule 5, Section 1) applied, as this would improperly expand the jurisdictional limits set by statute. The Judiciary Act of 1948 confines a CFI’s power to issue writs like certiorari and prohibition to its own province or district. Allowing the Manila CFI to issue such writs against officers acting in Cebu would contravene this statutory apportionment of jurisdiction. Thus, the Manila court correctly dismissed the case for wrong venue.