Title
Capitol Hills Golf and Country Club, Inc. vs. Sanchez
Case
G.R. No. 182738
Decision Date
Feb 24, 2014
Stockholder challenges corporate meetings, court orders document production; petitioners delay compliance, face sanctions upheld by higher courts.
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Case Digest (G.R. No. 182738)

Facts:

  1. Initiation of the Case: On July 1, 2002, respondent Manuel O. Sanchez, a stockholder of petitioner Capitol Hills Golf & Country Club, Inc., filed a petition to nullify the annual and special meetings of stockholders held on April 23, 2002, and May 21, 2002.
  2. Motion for Production of Documents: On August 12, 2002, Sanchez filed a Motion for Production and Inspection of Documents, which the court granted on September 10, 2002. The order required the corporation to produce:
    • The list of stockholders as of March 2002.
    • All proxies received by the corporation.
    • Specimen signatures of stockholders.
    • Tape recordings of the stockholders' meetings.
  3. Delays and Non-Compliance: Despite the court order, petitioners repeatedly delayed compliance. Inspections scheduled for September 30, 2002, and January 22, 2003, did not occur due to petitioners' motions for deferment.
  4. Further Court Orders: On September 3, 2007, the trial court reiterated its September 10, 2002, order and warned petitioners of contempt and fines for non-compliance.
  5. Appeal to the Court of Appeals: Petitioners challenged the trial court's orders via a petition for certiorari, but the CA affirmed the lower court's decision.

Issue:

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Ruling:

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Ratio:

  1. Authority to Order Production of Documents: The trial court's order for the production of documents was based on Rule 27 of the Rules of Civil Procedure and the Interim Rules Governing Intra-Corporate Controversies. The court has the authority to compel parties to produce relevant documents for inspection.
  2. Sanctions for Non-Compliance: The threatened sanctions, including fines for non-compliance, were within the court's discretion under Section 4 of Rule 3 of the Interim Rules and Section 3 of Rule 29 of the Rules of Civil Procedure. The court may impose sanctions, including fines, for failure to comply with discovery orders.
  3. Due Process: Petitioners were not denied due process as they were given opportunities to comply with the court's orders and to file motions for reconsideration. The court's warning of sanctions was a reminder of the consequences of non-compliance, not a final judgment of contempt.
  4. Proper Remedy for Contempt: If petitioners were to be cited for contempt, the proper remedy would be an appeal under Rule 41 of the Rules of Court, not a petition for certiorari under Rule 65.


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