G.R. No. L-2120 - Alvarez vs. Ibanez

Petitioners, Jose Alvarez et al., sought to declare the Court of First Instance of Laguna without jurisdiction to take cognizance of Civil Case No. 9039, entitled "Colegio de San Jose versus Jose H. Guevara, et al."
They also prayed for the annulment of the orders issued on December 10, 1947 (appointing a receiver), January 22, 1948, and February 13, 1948.

On December 10, 1947, the lower court appointed Segundo C. Mastrili as receiver.
The receiver, with the assistance of MP soldiers, allegedly compelled petitioners to deliver their palay crops.
Petitioners filed an urgent motion for reconsideration of the receiver's appointment on December 22, 1947, but the court did not act on it.

On December 31, 1947, petitioners moved to dismiss the complaint, but the motion was denied on January 22, 1948.
Their motion for reconsideration of the denial was also denied on February 13, 1948.
Petitioners argued that the orders were illegal and void because:
1. The receiver was appointed without complying with legal requirements.
2. The complaint did not specify the lands, improvements, or crops being litigated.
3. The lower court lacked jurisdiction due to the moratorium law, prescription of the judgment, and lack of specific allegations against petitioners.
4. The Colegio de San Jose, the plaintiff, was allegedly non-existent, having been abolished in 1767.
5. Petitioners were not parties in the original case (Civil Case No. 6663).

Respondents argued that the lower court had jurisdiction over the subject matter.
They claimed petitioners were either parties, privies, successors, agents, or tenants of the original plaintiff in Civil Case No. 6663.
The appointment of the receiver was justified under Section 1 of Rule 61 of the Rules of Court, as petitioners were insolvent and refused to apply the land's produce to satisfy the judgment.
They denied that the judgment was transferred to the government or covered by the moratorium law.

A petition for prohibition with preliminary injunction was filed in the Supreme Court on December 24, 1947, by other defendants in Civil Case No. 9039.
The lower court suspended action on petitioners' motion for reconsideration pending the Supreme Court's decision.

Whether the lower court had jurisdiction over Civil Case No. 9039.
Whether the appointment of the receiver and the subsequent orders were valid.
Whether the petitioners were entitled to relief from the Supreme Court without first exhausting remedies in the lower court.

Justice Perfecto dissented, arguing that the status quo should be maintained, and petitioners should not be deprived of their crops or possession of the lands pending the resolution of the case.

Chief Justice Moran and Justices Pablo, Bengzon, Briones, and Tuason concurred with the majority decision.
Justice Paras concurred in the result.
Justice Feria also concurred in the dismissal of the petition.