G.R. No. 147746 - Perla Compania de Seguros Inc. vs. Spouses Sarangaya

Ten individuals are co-owners of six parcels of land along Espana, P. Campa, and Adelina Streets in Sampaloc, Manila.
Among these co-owners are the petitioners (Pablo de Jesus, Engracia de Jesus, and Manuela de Jesus) and respondent Maxima de Jesus, who acts as administratrix and attorney-in-fact.
Maxima de Jesus is entitled to a 10% compensation from the rental collections, as agreed upon by the co-owners.

The leased property is occupied by the Shell Company of the Philippines, Ltd., under a lease originally dated August 23 and 29, 1953.
The lease was renewed on January 10, 1966, with an increase in monthly rentals from P850.00 to P3,500.00 for the first 10 years and to P4,000.00 for the following 5 years.
Under the agreement, Shell issues a monthly check for P3,500.00 in the name of Maxima de Jesus, who then distributes the rental shares among the co-owners according to their respective fractions.

Petitioners sought to alter the payment method by instructing Shell to pay their rental shares directly to them, bypassing Maxima de Jesus.
This change would effectively deprive Maxima de Jesus of her 10% compensation—a fee based on the agreement for her role as administratrix.
The complaint filed on October 3, 1966, demanded an immediate injunction to stop Shell from changing the established payment process and, after judicial proceedings, a final judgment ordering the co-owners to pay the 10% commission to Maxima de Jesus.

The complaint prompted the City Court of Manila (Civil Case No. 153460) to issue, on a P500.00 bond, a writ of preliminary injunction on October 4, 1966.
The injunction mandated that Shell continue to issue the monthly rental check in the name of Maxima de Jesus exclusively, ensuring she could distribute the funds as agreed.
Subsequent motions by petitioners to dismiss the complaint and dissolve the injunction, as well as motions for reconsideration, were denied by the lower court.
The jurisdictional issues raised—particularly the appropriateness of the City Court’s exercise of jurisdiction over the specific performance claim and its power to issue injunctions—eventually reached the Supreme Court on a petition for certiorari and prohibition.

Whether the City Court of Manila had jurisdiction to entertain a complaint seeking specific performance of a contractual obligation, noting that the remedy (specific performance) is not susceptible to pecuniary estimation.
Whether jurisdiction over the subject matter can be inferred from the parties’ conduct or procedural posture, despite the clear constitutional and statutory definitions.

Whether the City Court was authorized to issue a writ of preliminary, and by extension final, injunction in a case primarily concerned with enforcing a specific performance claim.
Whether the statutory limits on the power of inferior courts, particularly city courts, preclude them from issuing injunctions in cases where the remedy sought is intrinsically non-divisible and tied to the nature of the contractual breach.