G.R. No. L-19278 December 29, 1962
CENTRAL BANK OF THE PHILIPPINES, COMMISSIONER OF CUSTOMS, and AGRO-INDUSTRIAL PRODUCTS, INC., petitioners, vs. ALFREDO CAJIGAL, et al., and the HON. DELFIN B. FLORES, Judge of CFI of Ilocos Norte, respondents.

FACTS

The case originated from a presidential approval of a proposal by Agro-Industrial Products, Inc. (Agro) to purchase low-grade tobacco from the Agricultural Credit and Cooperative Financing Administration (ACCFA) and to import foreign Virginia leaf tobacco for blending. Implementing this authority, the Central Bank allocated the import quota. This prompted Virginia tobacco farmers to file Civil Case No. 47659 in the Court of First Instance (CFI) of Manila against Agro and several government agencies, seeking to enjoin the importation and nullify the presidential authority. The Manila CFI initially issued a preliminary injunction but later lifted it upon Agro’s filing of a counterbond.
Subsequently, a group of farmers, including several who were also plaintiffs in the Manila case, filed a substantially identical complaint—Civil Case No. 3434—in the CFI of Ilocos Norte, seeking the same injunctive relief against the same importation. The defendants moved to dismiss on grounds of lack of jurisdiction and the pendency of the Manila case. Despite this, respondent Judge Delfin Flores issued a writ of preliminary injunction. The petitioners then filed this certiorari action before the Supreme Court.

ISSUE

Whether the Court of First Instance of Ilocos Norte had jurisdiction to issue a writ of preliminary injunction to restrain acts being committed outside its territorial jurisdiction, and whether it should have dismissed the case due to the pendency of a substantially identical action in the Manila court.

RULING

The Supreme Court granted the petition and annulled the writ issued by the Ilocos Norte court. The ruling was anchored on two clear legal principles. First, on territorial jurisdiction, the Court reiterated the doctrine established in Acosta vs. Alvendia that a CFI’s injunctive authority is limited to acts committed or about to be committed within its own province or district. The acts sought to be restrained—the importation and release of foreign tobacco—were to be performed at the Port of Manila, which is outside the territorial jurisdiction of the CFI of Ilocos Norte. Therefore, respondent Judge acted without jurisdiction in issuing the injunction.
Second, on the ground of lis pendens, the Court found the Ilocos Norte case barred by the prior pending action in Manila. The causes of action in both suits were identical, involving the same challenged presidential authority and the same importation transaction. The parties were also substantially the same, as several plaintiffs in the Ilocos Norte case were actively participating plaintiffs in the Manila case, and the other plaintiffs represented the identical interest of local tobacco farmers. Allowing the second suit to proceed would foster multiplicity of suits and potentially conflicting rulings. Consequently, the Supreme Court made permanent the preliminary injunction it had earlier issued against the enforcement of the Ilocos Norte writ.