Taxpayer filed before the RTC of Makati City a case to assail the decision of the City Treasurer
of the City of Tuguegarao, Cagayan which denied its protest contesting the demand letter and
statement of account for alleged local franchise taxes. The RTC dismissed the appeal on the
ground of lack of jurisdiction. On appeal to the CTA, the latter ruled that based on the
allegations and reliefs sought in taxpayer’s petition/appeal filed before the RTC of Makati City, it
is not simply a case seeking review of the decision of the City Treasurer. It is essentially an
action for injunction where the taxpayer seeks to control the acts of the City Treasurer of the
City of Tuguegarao. Considering that the petition/appeal prayed that the City Treasurer be
ordered to perform certain acts and also to refrain from doing a certain act, and considering the
allegations laid down by taxpayer in the petition/appeal concerning its rights under the Local
Government Code and ordinance, the case is essentially a principal action for injunction. The
Court which has jurisdiction over the action is the regional trial court belonging to the Second
Judicial Region. The RTC of Makati City did not err in dismissing the case because it has no
jurisdiction over an action for injunction where the acts sought to be enjoined are outside its
territorial region. (Philippine Long Distance Telephone Co., Inc. vs. City of Tuguegarao
CTA AC No. 103, July 11, 2014)
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