G.R. No. 208761 - People vs. Baraga y Arcilla

On April 16, 2012, Concorde Condominium, Inc. (CCI), representing itself and all unit owners of Concorde Condominium Building, filed a Petition for Injunction with Damages before the Regional Trial Court (RTC) of Makati City.
The petition sought the issuance of a Temporary Restraining Order (TRO), a Writ of Preliminary (Prohibitory) Injunction, and a Writ of Preliminary Mandatory Injunction against various respondents.
The petition was docketed as Civil Case No. 12-309 and raffled to Branch 149 of the Makati RTC, a branch designated as a Special Commercial Court.

CCI alleged that respondents, particularly Augusto H. Baculio and New PPI Corporation, misrepresented ownership of the disputed lots and Concorde Condominium Building and were pushing for its demolition, despite not being the rightful owners.
The petition also sought to enjoin respondent Asian Security and Investigation Agency from deploying its security guards within the building’s perimeter.
Moreover, it requested that Building Official Engr. Nelson B. Morales, Fire Marshal Supt. Ricardo C. Perdigon, and Regional Director F/C Supt. Santiago E. Laguna be restrained from acting on communications sent by Baculio concerning the revocation of building and occupancy permits and potential demolition.
Additional reliefs included holding respondents solidarily liable for actual, moral, and exemplary damages, attorney’s fees, litigation expenses, and costs of suit.

On April 24, 2012, during the RTC hearing, a witness (Mary Jane Prieto) testified on certain documents and fire deficiencies of the building.
The hearing was temporarily set aside for the court to formulate a remedial plan, leading to an Order directing:

An ocular inspection of the building by Fire Marshal Supt. Ricardo C. Perdigon and the Building Official of Makati City, represented by Atty. Fabio.
Submission of respective inspection reports by the next day.

The Order provided for a hearing on September 17, 2012, for unit owners to be heard in case the Building Official’s report was unfavorable, with a repair period of four months if remedial measures were applicable.
Concurrently, respondents Baculio and New PPI Corporation moved for re-raffling the case on April 25, 2012, arguing that a regular court (and not a Special Commercial Court) should have jurisdiction over the petition; however, the RTC denied the motion based on non-compliance with procedural requirements.

On May 8, 2012, respondents filed motions to vacate the RTC Order and dismiss the petition, contending lack of jurisdiction over an alleged intra-corporate controversy and failure on CCI’s part to exhaust administrative remedies.
In the RTC Order dated June 28, 2012, the petition was dismissed for lack of jurisdiction, noting:

The allegations admitted by CCI demonstrated that respondents were not the owners of the disputed lots and building.
There was an absence of intra-corporate relations necessary for assigning the case to a Special Commercial Court.

CCI filed a motion for reconsideration, which was denied, prompting the filing of a Petition for Review on Certiorari before the Supreme Court.

CCI maintained its rightful ownership over the common areas and the building as evidenced by provisions in its Master Deed and Amended By-laws.
It alleged fraudulent actions by PPI in altering the condominium plan and causing the issuance of separate titles, supported by favorable decisions in administrative cases (HLURB cases).
The petition detailed a series of misrepresentations and unauthorized acts by respondents including wrongfully claiming ownership, orchestrating unauthorized inspections, causing disruptions through security personnel, and attempting to facilitate demolition efforts.

Whether the Regional Trial Court, Branch 149 (designated as a Special Commercial Court), had the proper jurisdiction over CCI’s petition for injunction with damages.
Whether the designation as a Special Commercial Court inherently limits or diminishes the RTC’s general jurisdiction over an ordinary civil case.

Whether the petition for injunction with damages qualifies as an ordinary civil case or as an intra-corporate controversy.
Whether the allegations framed in the petition sustain a claim under the appropriate subject matter jurisdiction as provided by Section 19 of Batas Pambansa Blg. 129 and related statutory provisions.

Whether CCI failed to exhaust administrative remedies prior to filing the lawsuit—a contention raised by several respondents.
Whether the petition properly impleaded all indispensable parties, particularly concerning the issuance and revocation of building and occupancy permits.

Whether the actions and communications of respondents, particularly Baculio and New PPI Corporation, constitute misrepresentations that justify the issuance of injunction relief.
Whether the intervention of government officials (e.g., Engineering, Fire Protection, and Security agencies) based on these misrepresentations improperly affected the case’s procedural posture.