Case Digest (G.R. No. 168696) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In MA. LUTGARDA P. CALLEJA, et al. v. JOSE PIERRE A. PANDAY, et al. (G.R. No. 168696, February 28, 2006), respondents filed on May 16, 2005 before the Regional Trial Court of San Jose, Camarines Sur, Branch 58 (RTC-Br. 58) a petition for quo warranto with damages and an injunction, alleging that petitioners—who were incorporators and stockholders of St. John Hospital, Inc.—had with armed men unlawfully assumed the powers of the board of directors and officers from 1985 until May 2005. On May 24, 2005, RTC-Br. 58 ordered transfer of the case to RTC Branch 23 in Naga City, citing Section 7, Rule 66 of the 1997 Rules of Civil Procedure. The designated “special court” in Naga City, however, refused to receive it. RTC-Br. 58 then issued summons on petitioners, who answered on June 8, 2005, raising as affirmative defenses: improper venue, lack of jurisdiction, and wrong remedy. After memoranda, RTC Br. 58, on July 13, 2005, denied the motion to dismiss and remanded the case to RTC Bra Case Digest (G.R. No. 168696) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing of the quo warranto petition
- On May 16, 2005, respondents filed a verified petition for quo warranto with damages and prayers for mandatory and prohibitory injunctions and issuance of a TRO against petitioners in RTC-Br. 58, San Jose, Camarines Sur.
- Respondents alleged that petitioners forcibly usurped the powers of the duly constituted board of St. John Hospital, Inc., with the aid of armed men.
- Venue and transfer attempts
- On May 24, 2005, RTC-Br. 58 ordered the transfer of the case to the RTC in Naga City pursuant to Section 7, Rule 66, 1997 Rules of Civil Procedure, because petitioners were residents of Naga City.
- The Executive Judge of RTC, Naga City refused to receive the case folder, holding that improper venue is not a ground for transfer of a quo warranto case.
- Trial court proceedings in RTC-Br. 58
- Petitioners filed Answers raising affirmative defenses of improper venue, lack of jurisdiction, and wrong remedy (quo warranto).
- On July 13, 2005, RTC-Br. 58 denied the motions to dismiss and, invoking RA 8799, A.M. No. 00-11-03-SC, and its Interim Rules for Intra-Corporate Controversies, remanded the case to RTC Branch 23 (the “special court” in Naga City) and cancelled the scheduled hearing on the TRO and preliminary injunction.
- Elevation to the Supreme Court
- Petitioners filed a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, challenging the July 13, 2005 Order.
- Respondents opposed, arguing (a) the Order was interlocutory and non-appealable under Rule 45, (b) Rule 43 (CA review) was the proper remedy, and (c) the petition was a delaying tactic.
Issues:
- Whether an RTC branch without jurisdiction may remand a case to a co-equal court to cure venue and jurisdiction defects.
- Whether Administrative Circular No. 8-01 dated January 23, 2001 (effective March 1, 2001) applies to a case filed on May 16, 2005.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)