Title
Philippine International Fair, Inc. vs. Ibanez
Case
G.R. No. L-6448
Decision Date
Feb 25, 1954
A dispute arose over a 1953 essay contest award, with the winner challenged for violating rules. Courts upheld jurisdiction, allowing the case to proceed.
A

Case Digest (G.R. No. L-6448)

Facts:

Philippines International Fair, Inc., Luis Montilla, Federico Mangahas and Juan Collas v. Hon. Fidel Ibanez, as Judge of the Court of First Instance of Manila, Ponciano B. Jacinto and Simeon G. Del Rosario, G.R. No. L-6448. February 25, 1954, the Supreme Court En Banc, Padilla, J., writing for the Court.

The petitioners, Philippines International Fair, Inc. and certain officials, sponsored an essay contest entitled "500 Years of Philippine Progress" and promulgated written rules: length limits (800–1,000 words), requirement of historical correctness and formal type, open to all except the Fair’s staff, preliminary contests to be conducted by ten Manila newspapers, each awarding a first prize of P200 and certifying winners to the Fair, and a Grand Prize of P500 to be chosen by a three‑member jury appointed by the Fair’s Director General; the grand prize essay would become the property of the Fair and be printed in its official program.

Ten newspapers held preliminary contests and certified their winners to the Fair; the Director General appointed the three‑member jury which selected Enrique Fernandez Lumba (representing La Opinion) as the grand prize winner. Thereafter Ponciano B. Jacinto filed Civil Case No. 18255 in the Court of First Instance of Manila questioning the validity of the award; the trial court issued a writ of preliminary injunction upon the filing of a P1,000 bond.

The petitioners answered, asserting (1) lack of jurisdiction of the Court of First Instance over the subject matter and (2) that the complaint stated no cause of action; Simeon G. del Rosario sought leave to intervene and filed a complaint in intervention. The parties asked the trial court for a preliminary hearing on the jurisdictional question, invoking the rule in Ramon Felipe, Sr. v. Hon. Jose M. Leuterio (91 Phil. 482). After hearing, the Court of First Instance ruled that it had jurisdiction; a motion for reconsideration was denied.

The trial court dissolved its preliminary injunction upon the defendants’ filing of a P5,000 counter‑bond and set the merits hearing for January 29, 1953. The petitioners then filed a petition in the Supreme Court for a writ of certiorari and prohibition to enjoin the trial court from proceeding; the Supreme Court issued a preliminary injunction as prayed for pending resolution of the petition. The respondents opposed, alleg...(Subscriber-Only)

Issues:

  • Whether the Court of First Instance of Manila had jurisdiction to entertain Civil Case No. 18255 such that an extraordinary writ of certiorari or prohibition was inappropriate.
  • Whether the petitioners were entitled to a writ of certiorari and prohibition to enjoin the trial court from pro...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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