Case Digest (G.R. No. 224189)
Facts:
Bitmicro Networks, Inc., Bitmicro Networks International, Inc., Zophar Sante, Erwin Salazar and Maria Cecilia Martorillas v. Gilberto Cunanan and Jermyn Ong, G.R. No. 224189, December 06, 2021, Supreme Court Third Division, Carandang, J., writing for the Court. The petition for review on certiorari under Rule 45 was filed by petitioners BNI-US, BNII-PH, Sante, Salazar and Martorillas, assailing the Court of Appeals Decision dated September 17, 2015 and its Resolution dated April 15, 2016 in CA-G.R. SP No. 138521.Petitioners trace their claim to a Service Agreement between BNII-PH and BNI-US under which BNI-US owned all proprietary rights in technology developed by BNII-PH. Corporate control of BNII-PH became contested in 2013: the Bruce Group (led by Rey H. Bruce) and a rival group (the Sante Group) both claimed authority after a purported Special Shareholders’ Meeting on August 19, 2013 elected Stephen Uriarte and Zophar Sante to the board. Bruce purportedly directed employees not to disclose proprietary information, appointed respondent Gilberto Cunanan as Officer-in-Charge, and later was said to have been removed by BNI-US. Respondent Jermyn Ong resigned as IT Director effective August 31, 2013 and commenced new employment on August 22, 2013.
On September 11, 2013 petitioners (aligned with the Sante Group) filed a complaint in the Regional Trial Court (RTC), Taguig Branch 70, for tortious interference and quasi-delict against Bruce, Cunanan, Ong, and Armadillo Professional Security Agency, seeking temporary restraining orders, injunctions and damages for alleged interference with BNII-PH’s operations and BNI-US’s contractual rights under the Service Agreement. Defendants filed motions to dismiss, arguing the dispute was an intra-corporate controversy properly before a commercial court (Commercial Case No. 13-198 in RTC Taguig) and that petitioners lacked authority to sue for BNII-PH. The RTC denied the motions to dismiss in an Order dated June 18, 2014 and again denied reconsideration on October 2, 2014.
Respondents filed a petition for certiorari under Rule 65 with the Court of Appeals (CA). The CA, however, annulled and set aside the RTC’s orders and dismissed Civil Case No. 74080-TG for lack of jurisdiction in a Decision dated September 17, 2015, holding that the action was, in effect, an intra-corporate controversy because ...(Subscriber-Only)
Issues:
- Whether the complaint filed by petitioners involves an intra-corporate controversy that falls within the exclusive jurisdiction of the RTC sitting as a special commercial court.
- Whether petitioners’ action for tortious interference and quasi-delict is a purely civil action within the general jurisdiction of the RTC and therefore not an i...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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