Facts:

The case involves the Anderson Filipino-American Veteran Corps, Inc. (AFAG), which is the petitioner and appellant, and Mariano G. Pineda, the Securities and Exchange Commissioner, along with other respondents and appellees. The events leading to this case began on April 7, 1959, when the Solicitor General filed an administrative case against AFAG with the Securities and Exchange Commission (SEC) due to complaints from members of the Constabulary, the Army, and the National Bureau of Investigation. The complaints alleged that AFAG was unlawfully using military ranks and titles, conferring these ranks to its members without authority, misrepresenting itself as a recognized organization, and collecting fees based on these unlawful ranks. The SEC summoned the parties for an investigation on May 21, 1959.

In response, AFAG filed a petition for injunction in the Court of First Instance of Pasay on May 23, 1959, seeking to prevent the SEC from proceeding with the administrative ...

Facts:

1. Corporate Registration and Administrative Complaint

   • Petitioner, AFAG Veteran Corps, Inc. (AFAG), is a corporation registered with the Securities and Exchange Commission (SEC) in 1958.
   • On April 7, 1959, the Solicitor General filed an administrative case (S.E.C. Case No. 956) against AFAG, alleging several violations, including:
     • Unlawful use and conferment of military ranks and titles.
     • Misrepresentation to the public about being a recognized organization.
     • Collection of fees from members based on unlawfully conferred military ranks.
     • Acting as a military organization, engaging in seditious activities, and disturbing peace and order.

2. Legal Proceedings in Pasay Court

   • On May 23, 1959, AFAG filed a petition for injunction in the Court of First Instance of Pasay (Civil Case No. 1920-P) to prevent the SEC from proceeding with the administrative case, arguing lack of jurisdiction.
   • The SEC denied AFAG's motion for postponement, stating that most charges were not prejudicial and could be investigated.
   • On November 5, 1959, the Pasay court dismissed AFAG's petition, ruling that the SEC had authority to investigate and that the court could not enjoin the SEC. This decision became final as it was not appealed.

3. Petition in Manila Court

   • On March 19, 1960, AFAG filed a similar petition for injunction in the Court of First Instance of Manila (Civil Case No. 42794).
   • The Manila court dismissed the petition on May 7, 1960, and AFAG's motion for reconsideration was denied. AFAG appealed the decision.

4. Respondents' Arguments

   • Respondents argued that the appeal was untimely, as the petition was essentially for prohibition, requiring an appeal within 15 days.
   • They also contended that the petition was barred by prior judgment (the Pasay court's dismissal).

Issue:

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Ruling:

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Ratio:

1. Exclusive Jurisdiction of the Supreme Court

   • Under Section 1 of Rule 43 and Section 35 of Commonwealth Act No. 83, as amended, only the Supreme Court has the authority to review orders or decisions of the SEC.
   • Courts of First Instance do not have jurisdiction to review or enjoin the actions of the SEC, a semi-judicial body of equal rank.

2. Nature of the Petition

   • The petition, though labeled as one for injunction, effectively sought to prohibit the SEC from proceeding with its investigation. Such a remedy falls under the exclusive jurisdiction of the Supreme Court.

3. Res Judicata

   • The prior judgment of the Pasay court, which dismissed AFAG's petition on similar grounds, barred the subsequent petition in the Manila court.

4. Proper Remedy

   • If AFAG sought to challenge the SEC's actions, the proper remedy would have been a petition for prohibition filed directly with the Supreme Court, not with the Court of First Instance.