Case Digest (G.R. No. 6287)
Facts:
The Manila Railroad Company, G.R. No. L-6287, December 01, 1911, the Supreme Court, Moreland, J., writing for the Court (Torres, Johnson, Carson, and Trent, JJ., concurring).In December 1907 The Manila Railroad Company (plaintiff/appellee) instituted a condemnation action in the Court of First Instance (CFI) of the Province of Tarlac, alleging the lands sought for its Paniqui–Tayug railroad line were located in Tarlac. The complaint joined numerous defendants pursuant to Act No. 1258. After service, plaintiff took possession of the lands, built and operated the railroad line, and a commission to appraise damages was appointed and completed an extensive report. The CFI set a hearing on the commissioners’ report for 11 October 1909.
On 4 October 1909 the plaintiff notified defendants that it would move to dismiss the action on the ground that, contrary to the complaint, the lands were actually situated in the Province of Nueva Ecija, not Tarlac. The plaintiff made the motion; the trial court dismissed the action on that ground. The defendants (appealing here as appellants) contested dismissal; this appeal followed from the judgment of the Court of First Instance to the Supreme Court.
At trial and on appeal the parties invoked pertinent statutes and rules, principally Act No. 136 (secs. 55–56), Code of Civil Procedure provisions (notably Sec. 377 and secs. 241–246), and Act No. 1258 governing railroad condemnation. The CFI grounded its dismissal on the view that a CFI of one province lacks jurisdiction over actions affe...(Pro-only)
Issues:
- Does the Court of First Instance of one province lack subject-matter jurisdiction to entertain condemnation proceedings affecting land located in another province?
- Are the venue provisions of Sec. 377, Code of Civil Procedure and Sec. 3, Act No. 1258 jurisdictional (not waivable) or procedural/personal privileges that may be waived by the parties?
- Given the plaintiff’s conduct (bringing the action, taking possession, proceeding with commissioners’ inquiry) and the d...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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