GR L 24225; (February, 1968) (Digest)
G.R. No. L-24225 February 22, 1968
MANUEL CUDIAMAT, JOSE SUGAY and MARKETING & SERVICES, INC., petitioners, vs. HONORABLE GUILLERMO E. TORRES, Presiding Judge, Branch VII, Court of First Instance of Rizal, ITT (PHILIPPINES), INC., respondents.
FACTS
The Committee on Awards for the City of Manila, composed of petitioners Manuel Cudiamat (City Treasurer), Jose Sugay (Head Executive Assistant), and Jose Erestain (City Auditor), published an invitation to bid for the supply of a police call and signal box system. Among the bidders were petitioner Marketing & Services, Inc. and private respondent ITT (Philippines) Inc. The committee awarded the contract to Marketing & Services, Inc., which subsequently entered into a contract with the City of Manila and opened an irrevocable letter of credit in favor of its foreign supplier. ITT (Phil.) then filed a petition in the Court of First Instance of Rizal (Civil Case No. 8394) against the committee members and Marketing & Services, Inc., praying for a preliminary injunction against the implementation of the award, its annulment, damages, and a declaration that ITT was the winning bidder. The CFI of Rizal issued a writ of preliminary injunction on October 29, 1964. The respondents therein (herein petitioners) moved for reconsideration, which was denied, prompting them to file the present petition for certiorari and prohibition with the Supreme Court.
ISSUE
May a Court of First Instance issue a writ of preliminary injunction to be enforced outside the territorial boundaries of its province and district?
RULING
No. The Supreme Court ruled that the power of a court to issue an injunction is a matter of jurisdiction prescribed by legislative enactment. Section 44(h) of the Judiciary Act, as amended, provides that Courts of First Instance and their judges have the power to issue writs of injunction “in their respective provinces and districts.” This provision should not be confused with Section 2, Rule 58 of the Revised Rules of Court, which pertains to who may grant preliminary injunctions. The preliminary injunction that may be granted by a Court of First Instance is, in its application, co-extensive only with the territorial boundaries of the province or district in which that court sits. Since the injunction issued by the Court of First Instance of Rizal purported to restrain acts outside the province of Rizal (specifically, in the City of Manila), it was issued without jurisdiction and is therefore null and void. The Supreme Court made permanent its own previously issued preliminary injunction, enjoining the implementation of the CFI’s order and further proceedings in the case.