Case Digest (G.R. No. 182738)
Facts:
The case involves Capitol Hills Golf & Country Club, Inc. and Pablo B. Roman, Jr. as petitioners, and Manuel O. Sanchez as the respondent. The events leading to the case began on July 1, 2002, when Sanchez, a stockholder of Capitol Hills Golf & Country Club, Inc., filed a petition seeking to nullify the annual meeting of stockholders held on May 21, 2002, and a special meeting on April 23, 2002. The petitioners, along with their co-defendants, responded by filing an Answer with Counterclaims and subsequently a Motion for Preliminary Hearing of Defendants' Affirmative Defenses, which was denied by the Quezon City Regional Trial Court (RTC) on August 9, 2002. Following this, Sanchez filed a Motion for Production and Inspection of Documents, which the court granted on September 10, 2002, ordering the petitioners to produce specific documents related to the stockholders' meetings. The petitioners filed a motion for reconsideration of the August 9 order, which was ...
Case Digest (G.R. No. 182738)
Facts:
- 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.
- 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.
- 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.
- 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.
- 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:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- 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.
- 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.
- 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.
- 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.