69 De Jesus, et.al. vs. Garcia, G.R. No.

L-26816 February 28, 1967

Subject Matter: Jurisdiction of RTC: actions or cases incapable of pecuniary estimation; issue preliminary
or final injunction; Inferior courts i.e. city courts have no jurisdiction over actions or cases incapable of
pecuniary estimation and have no power issue preliminary or final injunction.

Facts:

Maxima De Jesus (respondent-complainant) was co-owner, administratrix, and attorney-in-fact of the six
parcels of land. Shell Company Philippines was the lessee of the property which has agreed to the
increase in the rentals of thereof from P850 to P3500 (first 10 years) and further to P4000 (subsequent 5
years). The rentals are divided proportionally among co-owners with Maxima receiving 10% of the rent
as compensation. Pablo De Jesus et.al., in an effort to deprived Maxima of her 10% compensation
surreptitiously filed a complaint against Shell Philippines ordering her not to pay share of their rentals to
Maxima anymore but to directly to them. Thus, Maxima filed before City Court of Manila a motion for
preliminary or final injunction. Thereafter, City Court of Manila issued ex parte, through a bond, a writ of
injunction ordering Shell Philippines to refrain from modifying present forma de pago and to pay rentals
to Maxima De Jesus.

Issue:

1. WON city courts have jurisdiction over actions incapable of pecuniary estimation.
2. WON city courts have power to issue preliminary injunctions.

Ruling:

1. The averments of the complaint, taken as a whole, are what determine the nature of the action,
and therefore, the court's jurisdiction. A careful and considerate examination of the complaint as a
whole shows fact that plaintiff Maxima de Jesus asks that these defendants comply faithfully with
their respective commitments. Implicit, too, in the complaint is the demand that her said co-
owners recognize her as administratrix. It is in the context just recited that plaintiff's action below
comes within the concept of specific performance of contract. And in this posture, we express the
view that jurisdiction resides in the court of first instance. For, specific performance — the
subject of the litigation — "is not capable of pecuniary estimation".

The city court has no jurisdiction of a suit for specific performance of a contract, although the
damages alleged for its breach, if permitted, are within the amount of which that court has
jurisdiction.

2. Nor does the law grant the city courts power to take cognizance of a case for final injunction. On
the contrary, such authority is expressly granted by statute to courts of first instance (RTC) in the
exercise of their original jurisdiction. And the city court is without jurisdiction to hear and
determine the case for final injunction (against Shell).

However power to issue preliminary injunction, can be exercise by city courts and other inferior
only to cases involving forcible entry. Temporary injunctions could also be issued in cases other
than forcible entry; but then only municipal courts in provincial capitals are privileged to grant
the same, and solely in the absence of the district (RTC) judge.