G.R. No. L-7688, March 29, 1912
MANILA ELECTRIC RAILROAD AND LIGHT COMPANY vs. SIMPLICIO DEL ROSARIO, ET AL.

FACTS

Doroteo Jose had a contract with the Manila Electric Railroad and Light Company (MERALCO) for electricity. MERALCO suspected Jose of stealing electricity via a meter-tampering device, leading to a criminal complaint that was dismissed and Jose was acquitted. Subsequently, MERALCO billed Jose for the allegedly stolen electricity and, upon his refusal to pay, disconnected his service. Jose filed a complaint in the Court of First Instance (CFI) of Manila for a writ of mandamus to compel MERALCO to restore service, and obtained a preliminary mandatory injunction ordering MERALCO to continue supplying electricity pending resolution of the mandamus case. MERALCO then petitioned the Supreme Court for a writ of certiorari, arguing that the CFI judge exceeded his jurisdiction by issuing a preliminary mandatory injunction, claiming such relief is not authorized under the law.

ISSUE

Whether a Court of First Instance has jurisdiction to issue a preliminary mandatory injunction.

RULING

Yes. The Supreme Court held that CFIs, as courts of general and unlimited original jurisdiction, possess the inherent power to issue preliminary injunctions, both preventive and mandatory, as a necessary incident to their equitable jurisdiction to preserve the status quo and secure the rights of litigants pending final adjudication. While the Code of Civil Procedure primarily details the procedure for preventive injunctions, the power to issue mandatory injunctions is inferred from the general jurisdiction conferred by law ( Act No. 136 , Section 55). The Court emphasized that preliminary mandatory injunctions are proper in cases of extreme urgency, clear rights, continuing injury, and where no other adequate remedy existssuch as when a public utility arbitrarily withholds essential services. In this case, MERALCO’s disconnection was arbitrary, Jose faced serious continuing injury, and mandamus alone was inadequate for immediate relief. Thus, the CFI acted within its jurisdiction. The petition for certiorari was dismissed.