G.R. No. L-44649 April 15, 1988
DAYLINDA A. LAGUA, MANUEL P. LAGUA, HONORATO ACHANZAR and RESTITUTO DONGA, petitioners, vs. HONORABLE VICENTE N. CUSI, JR., in his capacity as Presiding Judge of the Court of First Instance of Davao City, Branch I, CONSTANCIO MAGLANA and the EASTCOAST DEVELOPMENT ENTERPRISES, respondents.

FACTS

The petitioners filed a complaint for damages against the private respondents, Eastcoast Development Enterprises and its manager Constancio Maglana. The petitioners alleged that the respondents, through their security personnel, illegally closed a logging road on January 1, 1976, specifically to prevent the trucks of petitioners Achanzar and Donga, represented by spouses Daylinda and Manuel Lagua, from hauling logs to a waiting vessel. This act disrupted their loading operations. Despite a directive from the Bureau of Forest Development (BFD) on January 2, 1976, ordering the road reopened, the respondents closed it again on January 3, 1976, upon Maglana’s orders, further obstructing the petitioners’ business.
The private respondents moved to dismiss the complaint on grounds of lack of jurisdiction and lack of cause of action. They argued that the legality of closing a logging road was a matter within the primary jurisdiction of the Bureau of Forest Development under Presidential Decree No. 705. They also contended that petitioner Daylinda Lagua lacked capacity to sue as she was not a registered log dealer. The trial court granted the motion, dismissing the complaint. It ruled that the BFD must first make a positive finding on the illegality of the closure before a civil action for damages could prosper.

ISSUE

Whether the trial court committed grave abuse of discretion in dismissing the complaint for damages on the ground of lack of jurisdiction.

RULING

Yes, the trial court committed grave abuse of discretion. The Supreme Court ruled that the civil court retains jurisdiction over the action for damages. The core issue was whether the petitioners could recover damages for the alleged tortious act of illegally blocking the road, which is a purely legal question under the Civil Code. Jurisdiction over such an action belongs to the regular courts. The Court clarified that not every activity within a forest area falls under the exclusive jurisdiction of the BFD. The respondents’ own actions contradicted their jurisdictional argument; they closed the road without prior BFD determination and defied the Bureau’s subsequent order to reopen it. They cannot invoke the BFD’s authority, which they initially disregarded, to oust the court’s jurisdiction.
Regarding the capacity to sue, the Court affirmed that spouses Daylinda and Manuel Lagua, as mere agents, were not the real parties-in-interest and could not sue for damages in their personal capacity. However, this defect did not warrant dismissal of the entire complaint. Since the real parties-in-interest, petitioners Achanzar and Donga, were co-plaintiffs, the trial court should have merely ordered the dropping of the Lagua spouses from the complaint under Rule 3, Section 11 of the Rules of Court, not dismissed the case outright. The petition was granted, the dismissal order set aside, and the case remanded for trial on the merits.