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### Facts
1. **Initial Seizure and Civil Case**:
– On April 3, 1964, Morabe, De Guzman & Co. filed Civil Case No. 56701 with the Court of First Instance (CFI) of Manila against Fisheries Commissioner Arsenio N. Roldan, Jr., seeking the recovery of the fishing vessel Tony Lex VI, which had been seized by the Philippine Fisheries Commission and the Philippine Navy.
– The company requested a writ of preliminary mandatory injunction on April 10, 1964, which was initially denied but was granted upon reconsideration on April 28, 1964, allowing the company to take possession of the vessel Tony Lex VI.
2. **Dismissal of Case No. 56701**:
– On December 10, 1964, Civil Case No. 56701 was dismissed by the CFI of Manila due to the respondent company’s failure to prosecute and the defendants’ failure to appear for the hearing. The vessel, however, remained in the respondent company’s possession.
3. **Subsequent Seizure**:
– On July 20, 1965, the Fisheries Commissioner requested the Philippine Navy to apprehend the vessels Tony Lex VI and Tony Lex III for suspected violations of the Fisheries Act.
– On August 5 or 6, 1965, both vessels were seized by the Philippine Navy for illegal fishing with dynamite, and associated evidence was found on board.
4. **Criminal Charges Filed**:
– Criminal informations were filed against the crew members on September 30, 1965, in the CFI of Palawan for illegal fishing using dynamite. The Palawan court ordered the Navy to hold the vessels in custody.
5. **Second Civil Case**:
– On October 2, 1965, the respondent company filed Civil Case No. 62799 with the CFI of Manila, seeking recovery of the vessels.
– The petitioners opposed the issuance of a preliminary mandatory injunction and submitted various documents challenging the respondent company’s claims.
6. **Issuance of Preliminary Injunction**:
– On October 18, 1965, the CFI of Manila, presided over by Hon. Francisco Arca, granted the preliminary mandatory injunction, ordering the release of the vessels upon securing a bond of ₱5,000.
7. **Procedural History**:
– Petitioners filed a motion for reconsideration on October 19, 1965, against the issuance of the preliminary injunction. On November 23, 1965, this motion was denied.
– Petitioners then filed a petition for certiorari and prohibition with the Supreme Court to annul the CFI of Manila’s order and writ.
### Issues
1. **Jurisdiction**:
– Did the Manila CFI have jurisdiction to issue a preliminary mandatory injunction concerning vessels under the custody of the Palawan CFI?
2. **Grave Abuse of Discretion**:
– Did Hon. Francisco Arca act with grave abuse of discretion in issuing the preliminary mandatory injunction and denying the motion for reconsideration?
3. **Seizure Validity**:
– Were the vessels lawfully seized and subject to the jurisdiction of the Fisheries Commissioner and the Philippine Navy under existing fisheries laws?
### Court’s Decision
1. **Jurisdiction**:
– The Supreme Court ruled that the Manila CFI acted without jurisdiction in issuing the writ of preliminary mandatory injunction, as the vessels were already under the jurisdiction of the Palawan CFI per orders dated October 2 and 4, 1965. Possession acquired by the Palawan court cannot be interfered with by another court of concurrent jurisdiction.
2. **Grave Abuse of Discretion**:
– It was determined that Hon. Francisco Arca exercised grave abuse of discretion by not reconsidering his October 18, 1965, order, especially after being informed of the Palawan court’s orders to retain custody of the vessels.
3. **Seizure Validity**:
– The seizure by the Fisheries Commissioner and the Philippine Navy was deemed valid under Republic Act No. 3512 and other related laws. The vessels were engaged in illegal fishing activities and did not possess necessary licenses, making them liable for seizure and forfeiture.
### Doctrine
– Courts of coordinate jurisdiction cannot interfere with each other’s orders or judgments concerning property under custodia legis.
– The jurisdiction over criminal offenses and their instruments belongs to the court where the offense was committed.
– Fishing vessels engaged in illegal activities are subject to warrantless search and seizure.
### Class Notes
– **Key Legal Elements**:
– **Jurisdiction**: Recognizing the court’s authority over the offense location.
– **Grave Abuse of Discretion**: Handling of judicial misconduct and erroneous legal actions.
– **Seizure and Forfeiture**: Under R.A. No. 3512, statutory provisions for seizure of vessels involved in illegal fishing.
– **Statutory Provisions**:
– R.A. No. 3512: Fishery laws enforcement authority.
– R.A. No. 4003 (Fisheries Act): Prohibition and penalties for illegal fishing.
– Tariff and Customs Code §§ 903, 2210: Search and seizure of vessels violating customs law.
– Section 6, Rule 113 (Revised Rules of Court): Lawful arrest without a warrant.
### Historical Background
– This ruling is situated in the context of the Philippine government’s efforts to strengthen the enforcement of fisheries laws during the 1960s amid widespread illegal fishing activities. It underscores the comprehensive powers granted to the Fisheries Commission and accompanying agencies in safeguarding marine resources and underscores the judiciary’s approach to jurisdictional boundaries and intra-court interference.
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