Case Digest (G.R. No. L-34298)
Facts:
- The case involves Alger Electric, Inc. (petitioner) and Northern Cement Corporation (respondent).
- The Supreme Court of the Philippines rendered its decision on February 28, 1985.
- Alger Electric was granted a legislative franchise under Republic Act No. 3826 on June 22, 1963, allowing it to operate an electric power system in certain municipalities in La Union and Pangasinan.
- On August 16, 1968, Northern Cement Corporation entered into a contract with the National Power Corporation (NPC) for direct electric power supply to its cement plant in Labayog, Sison, Pangasinan.
- Alger Electric filed a petition for prohibition with a preliminary injunction against Northern and NPC, claiming the contract was illegal under Section 2 of Republic Act No. 3826.
- The trial court denied the request for a preliminary injunction, leading to Northern's motion to dismiss based on several grounds, including lack of jurisdiction and the unconstitutionality of Section 2.
- The trial court later admitted an amended complaint from Alger Electric, prompting Northern to appeal to the Court of Appeals, which ruled in favor of Northern, stating the trial court lacked jurisdiction.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Court of First Instance of Manila had jurisdiction over the original complaint.
- The Court held that the trial court was justified in admitting the amended complaint.
- The Court did not find it necessary to rule on the constitutionality of Sect...(Unlock)
Ratio:
- The Supreme Court emphasized that the nature of an action is determined by the facts alleged in the complaint, not merely by its title.
- The original complaint effectively sought the annulment of a contract, which fell within the trial court's jurisdiction.
- Amendments to the complaint did not alter the or...continue reading
Case Digest (G.R. No. L-34298)
Facts:
The case involves Alger Electric, Inc. (petitioner) and Northern Cement Corporation (respondent), with the decision rendered by the Supreme Court of the Philippines on February 28, 1985. Alger Electric, Inc. was granted a legislative franchise under Republic Act No. 3826 on June 22, 1963, allowing it to construct, maintain, and operate an electric light, heat, and power system in specific municipalities in La Union and Pangasinan. On August 16, 1968, Northern Cement Corporation entered into a contract with the National Power Corporation (NPC) for the direct supply of electric power to its cement plant in Labayog, Sison, Pangasinan. Alger Electric filed a petition for prohibition with a preliminary injunction against both Northern and NPC in the Court of First Instance of Manila, claiming that the contract was illegal under Section 2 of Republic Act No. 3826, which required NPC to negotiate with and supply power through Alger Electric if it had established lines in the area. The trial court denied the request for a preliminary injunction, leading to Northern's motion to dismiss the case on several grounds, including lack of jurisdiction and the unconstitutionality of Section 2 of the franchise. The trial court eventually admitted an amended complaint from Alger Electric, but Northern appealed this decision to the Court of Appeals, which ruled in favor of Northern, stating that the trial court lacked jurisdiction over the original complaint since...