GR L 3378; (December, 1907) (Digest)
G.R. No. L‑3378
December 5 1907
PARTIES
Petitioner: José Castaño, attorney‑in‑fact of José Fernandez
Respondents: Charles S. Lobinger, Judge of First Instance, Twelfth Judicial District; Manuel Araujo
FACTS:
1. Manuel Araujo, a resident of Tacloban (Leyte), was sued before the Justice of the Peace (JP) of Manila for a debt.
2. A judgment was rendered by the Manila JP against Araujo.
3. A petition was filed in the Court of First Instance (CFI) of Leyte seeking (a) a writ of certiorari to review the JP’s judgment and (b) a preliminary injunction enjoining the JP, the relator, and others from executing that judgment.
4. The Leyte CFI Judge granted the writ of certiorari and the injunction.
5. The Manila JP and other respondents moved to quash the injunction and certiorari on the ground that the Leyte CFI lacked jurisdiction over a proceeding arising from a JP of another district.
ISSUE:
Whether the Court of First Instance of Leyte had jurisdiction to (1) entertain a petition for certiorari against the judgment of the Justice of the Peace of Manila, and (2) issue a preliminary injunction suspending the execution of that judgment.
RULING:
1. Jurisdictional limitation Under § 163 and § 226 of the Civil Code of Procedure, a CFI may grant a preliminary injunction only in actions pending within its own territorial district. The same limitation applies to the issuance of a writ of certiorari; the proper reviewing court is the CFI of the district wherein the questioned decision was rendered (Manila), or its immediate superior.
2. Absence of authority The Leyte CFI was not the court designated by law to review or enjoin the act of a Manila JP. Consequently, the Leyte judge exceeded his statutory authority by granting both the writ of certiorari and the injunction.
3. Effect The petition for certiorari is dismissed, and the preliminary injunction is set aside. The Leyte CFI Judge is ordered to desist from any further interference with the execution of the Manila JP’s judgment.
Doctrine
A judge may not exercise remedial powers (certiorari, prohibition, injunction) over a decision rendered by a tribunal situated in another judicial district. Challenges to the jurisdiction of the original adjudicating tribunal must be raised before that tribunal; once a judgment is entered, the proper remedy is appeal to the designated appellate court, not a special remedy before an unrelated CFI.