G.R. No. L-26829. December 27, 1979.
GONZALO B. MENDOZA, doing business under the firm name “GONZALO B. MENDOZA & SONS”, and CONRADO G. GENILLO, in his official capacity as Division Superintendent of Schools for Pangasinan, petitioners, vs. HON. FERNANDO A. CRUZ, Presiding Judge of the Court of First Instance of Caloocan City, and RESTITUTO H. SAMSON, JR., under the firm name “GLO-ZEN SUPPLIERS”, respondents.

FACTS

The Division Superintendent of Schools for Pangasinan, Conrado G. Genilo, conducted a public bidding for school furniture. Gonzalo B. Mendoza submitted the lowest bid and was awarded the contract. He subsequently made substantial deliveries. Restituto H. Samson, Jr., an unsuccessful bidder, filed a petition for injunction with the Court of First Instance (CFI) of Rizal, Caloocan City, to restrain Mendoza from further deliveries and Genilo from making payments, alleging the bidding was spurious. The respondent judge issued an ex parte writ of preliminary injunction based on a bond.
Petitioners moved to lift the injunction, arguing the CFI of Caloocan City lacked jurisdiction because the acts to be restrained—deliveries in Dagupan City and payments from Pangasinan school funds—were entirely outside its territorial boundaries. The judge denied the motion. Petitioners thus filed this certiorari petition to annul the injunction order. During these proceedings, respondent Samson moved to dismiss his own Caloocan case, intimating he would refile in the proper court, rendering the primary jurisdictional question moot.

ISSUE

Whether the Court of First Instance of Caloocan City had jurisdiction to issue a writ of preliminary injunction restraining acts to be performed outside its territorial jurisdiction.

RULING

The Supreme Court ruled that the respondent judge acted without jurisdiction. The legal principle is settled that a court’s authority to issue injunctive writs is confined to acts committed or to be committed within its territorial jurisdiction. The acts sought to be enjoined—Mendoza’s deliveries in Dagupan City and Genilo’s disbursement of Pangasinan school funds—were unequivocally within the province of Pangasinan. Therefore, the CFI of Caloocan City had no power to restrain them.
However, since the private respondent had already moved to dismiss his own case in Caloocan, the main petition was rendered moot and academic. The Court dismissed the petition and lifted the preliminary injunction it had previously issued. The Court declined to adjudicate the petitioners’ claim for damages contained in their Reply. It noted that such a claim arising from an allegedly wrongful injunction must be pursued in the principal action itself, as per Section 20, Rule 57 of the Rules of Court, requiring an application filed before final judgment. Furthermore, it was disclosed that the petitioners had already raised this claim for damages in a separate injunction case filed by Samson in the CFI of Pangasinan. Costs were imposed on the private respondent.