Primary Holding

Where a Court of First Instance has jurisdiction over the subject matter and person, its decision on any question pertaining to the cause, however erroneous, cannot be reviewed by certiorari but must be corrected by appeal.

Background

The case arose from a dispute over a cockpit license in Caloocan, where the municipal president refused to issue a license to Constancio Joaquin. The Court of First Instance issued an ex parte mandatory injunction requiring the issuance of a provisional license during the pendency of the action.

Facts

• 1. Constancio Joaquin sought a cockpit license in Caloocan
• 2. Municipal authorities refused to issue the license
• 3. Joaquin filed mandamus action against Municipal President Herrera
• 4. Court of First Instance issued ex parte mandatory injunction for provisional license
• 5. Herrera filed certiorari petition with Supreme Court

Arguments of the Petitioners

• 1. Court exceeded jurisdiction by issuing mandatory injunction as licensing authority belongs to municipal council
• 2. Court exceeded jurisdiction by issuing injunction ex parte without notice
• 3. Previously issued license was cancelled by municipal ordinance
• 4. Another pending action between same parties made court lack jurisdiction

Arguments of the Respondents

• 1. Court had proper jurisdiction over mandamus actions
• 2. Court had authority to issue provisional remedies
• 3. Ex parte order was within court's discretion

Issues

• 1. Whether certiorari is proper remedy to question Court of First Instance's issuance of mandatory injunction
• 2. Whether errors in judgment constitute excess of jurisdiction

Ruling

• 1. The Supreme Court denied the petition for certiorari
• 2. Certiorari only reviews jurisdictional errors, not errors of judgment
• 3. Court of First Instance had jurisdiction over mandamus actions
• 4. Having jurisdiction, errors in exercise of that jurisdiction must be corrected by appeal
• 5. Mere irregularity or error does not constitute excess of jurisdiction
• 6. Pending related case does not affect court's jurisdiction to act

Doctrines

• 1. Doctrine of Jurisdiction: The authority to hear and determine a cause - the right to act in a case
• 2. Doctrine on Certiorari: Limited to correction of jurisdictional defects, not errors in judgment
• 3. Doctrine on Appeals: Proper remedy for correction of errors within jurisdiction

Key Excerpts

• 1. "Jurisdiction is the authority to hear and determine a cause —the right to act in a case. Since it is the power to hear and determine, it does not depend either upon the regularity of the exercise of that power or upon the rightfulness of the decisions made."
• 2. "The power to decide correctly and to enforce a decision when correctly made necessarily implies the same power to decide incorrectly and to enforce a decision when incorrectly made."

Precedents Cited

• 1. Chase vs. Christianson (41 Cal., 253): Distinguished between jurisdiction and exercise of jurisdiction
• 2. Freeman vs. Thompson (53 Mo., 183): Explained difference between void and voidable acts
• 3. Yangco vs. Rohde (1 Phil. Rep., 404): Established limits of jurisdiction in alimony cases
• 4. Multiple other Philippine Supreme Court cases establishing certiorari doctrine

Statutory and Constitutional Provisions

• 1. Section 514 of Code of Civil Procedure: Grounds for certiorari
• 2. Section 174 of Code of Civil Procedure: Appointment of receivers
• 3. Municipal Code Section 40(j): Authority over cockpit licenses