Title
Cudiamat vs. Torres
Case
G.R. No. L-24225
Decision Date
Feb 22, 1968
A bidding dispute arose over a Manila police system contract; Rizal court’s injunction was annulled by the Supreme Court for exceeding territorial jurisdiction.
preliminary injunction
court of first instance
null and void
A

Case Summary (G.R. No. L-24225)

Procedural and Contractual Antecedents

On 8 May 1964, the committee on awards for the City of Manila published an invitation to bid for the supply of the police call and signal box system. Marketing & Services, Inc. and ITT (Phil.) among other companies answered the invitation and submitted their respective proposals. After evaluating the bids, the committee decided in favor of Marketing & Services, Inc. The awardee entered into a contract with the City of Manila on 3 September 1964 and, on 22 September 1964, opened an irrevocable letter of credit in favor of its foreign supplier.

ITT’s Court Challenge and the Issuance of Preliminary Injunction

On 25 September 1964, respondent ITT (Phil.) filed a petition with the Court of First Instance of Rizal, docketed as Civil Case No. 8394, against the members of the committee on awards in their official and personal capacities, and against Marketing & Services, Inc. It prayed for the issuance of a preliminary injunction against the implementation of the award and, after hearing, for the annulment of the award, damages, and a declaration that it be adjudged as the winning bidder and entitled to the award. ITT alleged, among others, that Marketing & Services, Inc. was disqualified as an irresponsible bidder under the conditions of the invitation to bid; that city officials violated a statutory prohibition against public officials entering into a transaction manifestly and grossly disadvantageous to the government; and that ITT’s bid was not only the lowest in cost but also the most advantageous to the City of Manila.

After considering the verified petition and the opposition filed by the respondents therein, the Court of First Instance of Rizal issued a writ of preliminary injunction on 29 October 1964. Petitioners moved for reconsideration, but the motion was denied on 12 January 1965. They then filed the present petition with the Supreme Court.

Supreme Court’s Intervention Through Preliminary Injunction

By resolution dated 1 March 1965, the Supreme Court issued a writ of preliminary injunction, enjoining, until further orders, the implementation of the Court of First Instance of Rizal’s 29 October 1964 order in Civil Case No. 8394 and enjoining further proceedings in that case. The Supreme Court thereafter resolved the controversy by focusing on an issue deemed sufficient to dispose of the controversy.

The Controlling Issue

The Supreme Court framed the decisive question as follows: May a court of first instance issue a writ of preliminary injunction which will be enforced outside the territorial boundaries of its province and district? It treated the power to issue an injunction as jurisdictional, but subject to the territorial limitations prescribed by the governing rules.

Doctrinal Basis: Jurisdiction and Territorial Limitations for Preliminary Injunction

The Court held that the power of a court to issue an injunction is a matter of legislative enactment, citing Manila Railroad Co. vs. Atty. Gen., 20 Phil. 523. It further explained that while injunction power is conferred by law, its manner of exercise is prescribed by the Rules of Court and, specifically, by the territorial rule applicable to preliminary injunctions.

The Court referenced the then applicable provision under the Judiciary Act, as amended: Section 44 (h) of the Original Jurisdiction of Courts of First Instance, which provided that the courts and their judges “shall have power to issue” specified extraordinary writs “in their respective provinces and districts, in the manner provided in the Rules of Court.” The Court emphasized that this should not be confused with the rule on who may grant a preliminary injunction.

It contrasted this with Section 2, Rule 58 of the Revised Rules of Court (or Section 2, Rule 60 of the old Rules), which stated that a preliminary injunction may be granted by the judge of any court where the action is pending, by a Justice of the Court of Appeals or Supreme Court, or by the judge of a Court of First Instance in any action pending in an inferior court within his district. The Court held that the preliminary injunction that may be granted by a Court of First Instance under that rule is, in application, co-extensive with the territorial boundaries of the province or district where the court sits.

In support, the Court cited Acosta vs. Alvendia, et al., L-14598, 31 Oct. 1960, Alhambra Cigar & Cigarette Manufacturing Co., Inc. vs. National Administrator of Regional Office No. 2, etc., et al., L-20491, 31 Aug. 1965, and People et al. vs. Mencias, L-19633, 28 Nov. 1966.

Application to the Injunction Granted by the Court of First Instance of Rizal

Applying the rule to the facts, the Court found that the injunction issued by the Court of First Instance of Rizal “purports to restrain acts outside the province of Rizal.” Because the writ sought enforcement beyond the court’s territorial jurisdiction, the Court ruled that the injunction was null and void for want of jurisdiction.

Disposition and Effect of the Supreme Court’s Ruling

The Court thus made permanent the writ of preliminary injunction it had issued on 1 March 1965, and ordered that costs be charge

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