G.R. No. L-6287, December 1, 1911
THE MANILA RAILROAD COMPANY, plaintiff-appellee, vs. THE ATTORNEY-GENERAL, representing the Insular Government, et al., defendants-appellants.

FACTS

The Manila Railroad Company filed a condemnation proceeding in the Court of First Instance (CFI) of Tarlac to acquire land for its railway line from Paniqui to Tayug, alleging the land was situated in Tarlac. After the court appointed commissioners, received extensive evidence, and the commissioners submitted a detailed appraisal report, the plaintiff moved to dismiss the case. It had newly discovered that the land was actually located in Nueva Ecija, not Tarlac, and argued the Tarlac court lacked jurisdiction over land in another province. The trial court granted the dismissal for lack of jurisdiction. The defendants, who had participated fully and did not object to the venue, appealed.

ISSUE

Does a Court of First Instance of one province have jurisdiction over an action for condemnation of real property located in another province?

RULING

YES. The Supreme Court reversed the trial court’s dismissal. The jurisdiction of Courts of First Instance under Act No. 136 is universal and not territorially limited by province for civil actions involving title to or possession of real property. Jurisdiction over the subject matter is conferred by law and is not dependent on the location of the property. Procedural rules on venue (such as those in the Code of Civil Procedure) are designed for convenience and orderly administration, not to restrict the court’s fundamental jurisdiction. Since the defendants had voluntarily submitted to the court’s authority and were objecting to the dismissal (not the venue), the Tarlac court validly exercised jurisdiction. The Court clarified, however, that in condemnation cases, defendants may timely demand a change of venue to the province where their land lies for a more convenient trial, but no such demand was made here. The case was remanded for continuation.