G.R. No. L-22088. June 30, 1964.
CELESTINO C. ROSCA, ET AL., petitioners, vs. HON. FEDERICO C. ALIKPALA, ET AL., respondents.

FACTS

Petitioners, officers and members of the Caloocan City Police Department, filed a petition for prohibition and injunction before the Court of First Instance (CFI) of Manila. They challenged the actions of the Acting Commissioner of Civil Service, who had unilaterally re-examined their official status, ordered them to take qualifying examinations, and, upon their refusal, terminated their services effective immediately through a letter to the Caloocan City Mayor. Copies were sent to the City Treasurer and Auditor. The petitioners sought to declare their demotion and termination illegal and to enjoin the enforcement of the examination order and termination.
The CFI initially issued an order on August 5, 1963, granting a preliminary preventive injunction against the Commissioner and a preliminary mandatory injunction directing all respondents, including the Caloocan City officials, to restore petitioners to their positions and pay their salaries. However, on August 9, 1963, the court motu proprio modified this order by eliminating the mandatory injunction against the Caloocan City officials, ruling it lacked authority to enforce such a directive outside its territorial jurisdiction. Petitioners sought certiorari to reinstate the full original order.

ISSUE

Whether the Court of First Instance of Manila correctly modified its order by eliminating the mandatory injunction against the Caloocan City officials on the ground of lack of territorial jurisdiction.

RULING

The Supreme Court dismissed the petition. The legal logic centers on the principle of judicial efficacy and the nature of the relief sought. The Court reasoned that the mandatory directive against the Caloocan City officials was rendered unnecessary and superfluous by the directive maintained against the Acting Commissioner of Civil Service. The termination of petitioners’ services was directly caused by the Commissioner’s orders, which the city officials merely obeyed. Therefore, by enjoining the Commissioner from continuing the re-examination and termination process and ordering him to restore the petitioners, the legal objective was effectively achieved.
The Commissioner, being the principal author of the contested actions, had the authority and obligation to recall or hold in abeyance his directives to the city officials and to effectuate the petitioners’ reinstatement pending the main case. Consequently, the CFI’s modification, while based on a jurisdictional concern, did not prejudice the petitioners because the relief against the Commissioner was sufficient to provide the necessary remedy. The Supreme Court found no need to adjudicate the territorial jurisdiction issue further, as the practical outcome secured the petitioners’ interim restoration through the order binding the Commissioner.