FACTS:

Manila Suburban Railways Company (MSRC) is a foreign corporation with its main office in Manila. It operates street-car lines in Manila and Pasig but has no general agent or official residing in Pasig, only an inspector.

Fermin Poson filed a civil action for P400 damages against MSRC (identified as “La Empresa del Tranvia Electrico de Manila”) in the Justice of the Peace (J.P.) court of Pasig, presided over by Engracio Santiago. MSRC alleged that it was never properly served with summons and that J.P. Santiago issued a default judgment against it for P400. MSRC sought a writ of prohibition and a preliminary injunction from the Supreme Court to prevent the execution of this judgment, claiming grave injustice and the J.P.’s inability to indemnify.

The deputy sheriff of Rizal testified that he initially delivered the summons to an MSRC inspector in Pasig, who directed him to the head office in Manila. In Manila, he showed the summons to M. F. Macling, a stenographer of the Manila Railroad Company, who later testified that he held no official position with MSRC and did not reside in Pasig. J.P. Santiago himself confirmed that the sheriff informed him the summons was served in Manila.

Section 14 of Act No. 1627 , as amended by Act No. 1862 , stipulates that the territorial jurisdiction of a Justice of the Peace is coextensive with his municipality, and civil process shall not be served outside its boundaries, except when a Judge of First Instance or, in his absence, the fiscal, certifies that the interests of justice require such service.

ISSUE:

Did the Justice of the Peace of Pasig have jurisdiction to render a judgment in a civil action when the summons was served outside his territorial jurisdiction (i.e., in Manila) without the required certification from a Judge of First Instance or fiscal?

RULING:

Yes. The Supreme Court ruled that J.P. Engracio Santiago acted with manifest lack of jurisdiction.

Under Section 14 of Act No. 1627 , as amended by Act No. 1862 , a Justice of the Peace’s territorial jurisdiction is limited to his municipality. Civil process cannot be lawfully served outside these boundaries unless a Judge of First Instance or the fiscal issues a certification stating that the interests of justice require such service.

In this case, the summons was undisputedly served in Manila, which is outside the territorial jurisdiction of the municipality of Pasig. Furthermore, there was no certification from a Judge of First Instance or the fiscal authorizing service outside Pasig’s boundaries. Consequently, the service of summons was invalid, and the Justice of the Peace court of Pasig never acquired jurisdiction over Manila Suburban Railways Company.

Therefore, the preliminary injunction issued by the Supreme Court against J.P. Engracio Santiago was made permanent, ordering him to desist and refrain from further proceedings in the civil action.