Case Digest (G.R. No. 206649)
Facts:
Forest Hells Golf and Country Club, Inc. v. Fil‑Estate Properties, Inc., G.R. No. 206649, July 20, 2016, Supreme Court Second Division, Del Castillo, J., writing for the Court. Petitioner Forest Hells Golf and Country Club, Inc. (FHGCCI), through shareholder and club member Rainier L. Madrid, sued respondents Fil‑Estate Properties, Inc. (FEPI) and Fil‑Estate Golf Development, Inc. (FEGDI) in the Regional Trial Court (RTC), Branch 74, Antipolo City, docketed as Civil Case No. 10‑9042, by filing a derivative Complaint for Specific Performance with Damages on April 21, 2010.The antecedent transactions began with a March 31, 1993 project agreement between Kingsville Construction and Development Corporation (Kingsville), Kings Properties Corporation (KPC) and respondent FEPI under which FEPI agreed to finance and develop parcels in Antipolo into the Forest Hills estate and to take an equity stake in the club; FEPI later assigned its rights and obligations to FEGDI on July 10, 1995. Madrid purchased two Class “A” shares and applied for club membership on July 19, 1996. Because the second 18‑hole golf course and other amenities were delayed, Madrid sent demand letters to FHGCCI’s Board on October 29, 2009 and March 15, 2010; the Board allegedly failed or refused to act.
Respondents answered, denying a cause of action, claiming no prior demand to them, asserting failure to exhaust intra‑corporate remedies and failure to implead the Board. The RTC, applying the relationship and nature‑of‑controversy tests (citing Reyes v. Hon. RTC of Makati, Br. 142), treated the Complaint as a derivative suit involving intra‑corporate controversy and on May 14, 2012 dismissed the case for lack of jurisdiction without prejudice to refiling in the proper special commercial...(Subscriber-Only)
Issues:
- Whether the RTC (Branch 74, Antipolo) had jurisdiction to hear petitioner FHGCCI’s Complaint for Specific Performance with Damages, or whether the action, being a derivative suit, falls within the jurisdiction of the special commercial courts designated under the interim rul...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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