Title
Mendoza vs. Cruz
Case
G.R. No. L-26829
Decision Date
Dec 27, 1979
A bidding dispute led to an injunction filed in Caloocan City, but the court lacked jurisdiction as acts occurred in Pangasinan. The case became moot after dismissal, with damages claims to be pursued separately.

Case Digest (G.R. No. L-26829)
Expanded Legal Reasoning Model

Facts:

  • Initiation of the Bidding Process
    • On August 5, 1966, Conrado G. Genilo, in his capacity as Division Superintendent of Schools for Pangasinan, issued a notice requesting sealed proposals for the furnishing and delivery of various school equipment (school desks, teacher’s tables, teacher’s aparadors, and teacher’s chairs).
    • Two bids were received: one from petitioner Gonzalo B. Mendoza (doing business as “Gonzalo B. Mendoza & Sons”) and the other from private respondent Restituto H. Samson, Jr. (doing business as “Glo-Zen Suppliers”).
  • Awarding of the Contract and Delivery of Equipment
    • The bid by Gonzalo B. Mendoza was lower, resulting in the award of the contract to him.
    • Deliveries of the school equipment commenced immediately after the award, and by the end of October 1966, the delivery was almost complete.
  • Filing of the Petition for Injunction
    • On November 2, 1966, immediately after the partial completion of deliveries, Restituto H. Samson, Jr. filed a petition for an injunction with a preliminary writ before the Court of First Instance of Rizal, Caloocan City.
    • The petition sought to restrain:
      • Gonzalo B. Mendoza from further deliveries of the school equipment.
      • Conrado G. Genilo, as Division Superintendent, from making payments for the delivered items using funds in his custody.
    • The basis for the petition was that the bidding process allegedly contained irregularities, suggesting a spurious public bidding crafted to prejudice the government.
  • Issuance and Defense of the Preliminary Injunction
    • The respondent Judge of the Court of First Instance, following the filing of a bond amounting to P2,000.00, issued the writ of preliminary injunction ex parte, thereby restricting the deliveries and disbursements mentioned.
    • Respondents later filed an urgent ex parte motion to lift the restraining order on the ground that:
      • The court lacked jurisdiction over acts committed or about to be committed outside its territorial boundaries.
      • There was an intention to file the matter in a court of proper jurisdiction.
    • The motion to lift the injunction was denied by the respondent Judge.
  • Subsequent Developments and Filing of the Instant Petition
    • The petitioners (Gonzalo B. Mendoza and Conrado G. Genilo) filed the instant petition to quash the restraining order issued on November 2, 1966, arguing that:
      • The acts to be restrained (deliveries and disbursements) occurred within Pangasinan, not within the jurisdiction of the Caloocan City court.
      • The respondent Judge lacked territorial jurisdiction to issue such a writ over acts committed in Pangasinan.
    • In response to the petition:
      • The respondents contended that the issue was now moot and academic because Restituto H. Samson, Jr. had taken steps toward filing a related case in the appropriate forum (Court of First Instance of Pangasinan, Special Civil Action No. 14589).
      • The respondents also pleaded that the claim for damages sought in the petitioners’ Reply was unfounded.
    • On January 17, 1967, the petitioners withdrew the cash bond that had been deposited for the issuance of the writ of preliminary injunction.
  • Claims for Damages and Relevant Procedure
    • In the petitioners’ Reply (filed on December 14, 1966), allegations were made that:
      • The wrongful filing of the injunction petition had caused actual damages and unnecessary litigation expenses, including attorney’s fees.
      • A specific monetary claim for exemplary and actual damages, attorney’s fees, and treble costs was advanced.
    • Restituto H. Samson, Jr. countered this claim in a rejoinder filed on January 4, 1967, contending that:
      • The petitioners’ claim for damages was without legal or factual basis.
      • The matter of damages was concurrently at issue in the related Special Civil Action No. 14589.
    • The rules governing claims for damages on account of injunction bonds were cited, specifically Sections 9 of Rule 58 and 20 of Rule 57 of the Rules of Court, which prescribe that:
      • Claims for damages should be presented in the principal action, and the final judgment on such claims must be rendered accordingly.
      • The application for damages must be made before trial, appeal, or execution of judgment, with proper notice to the affected parties.
  • Conclusion on the Instant Petition
    • The acts sought to be restrained by the writ (deliveries in Pangasinan and the related payments) lay outside the jurisdictional authority of the Caloocan City court.
    • Moreover, since the respondent had already initiated remedial steps (filing for dismissal and a separate case in the proper forum), the instant petition was rendered moot and academic.
    • Consequently, the petition was dismissed, and the previously issued writ of preliminary injunction was lifted, with costs imposed on respondent Restituto H. Samson, Jr.

Issues:

  • Jurisdictional Authority
    • Whether the respondent Judge of Caloocan City had proper territorial jurisdiction to issue a writ of preliminary injunction restraining actions (deliveries and payments) that were to be committed in Pangasinan.
  • Mootness of the Instant Petition
    • Whether the subsequent filing of a related case by respondent Restituto H. Samson, Jr. in the court of proper jurisdiction renders the instant petition to quash the injunction moot and academic.
  • Claim for Damages
    • Whether the petitioners’ claim for damages, arising from the alleged wrongful issuance of the injunction and subsequent financial losses, was proper and should be entertained under the Rules of Court.
    • Whether such claim should be included in the final judgment of the main action rather than through an independent proceeding.
  • Application of Procedural Rules
    • Whether the rules regarding the filing and determination of damage claims on the account of injunction bonds (as provided in Section 9 of Rule 58 and Section 20 of Rule 57) were properly applied in the context of the instant petition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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